News and Information
May 27, 2009

Lawyers who defer payments for services must comply with FTC Red Flags Rule by August 1, 2009.

The Federal Trade Commission has extended until August 1, 2009, enforcement of its “Red Flags Rule” that requires creditors who defer payments for goods and services — including lawyers — to develop and implement written programs to identify, detect, and respond to warning signs of identity theft.

The FTC has posted a template that explains the procedures needed to be taken under the Rule; it can be found at


ABA Red Flags Rule Fact Sheet (PDF file)

Description of Red Flags Requirements

FTC template

FTC Decision to Postpone Enforcement

ABA Press Release

ABA Letter to FTC (PDF file)

additional info


originally posted May 27, 2009

Updated: Jul 14, 2009