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Hogan Lovells Publications
"Red Flag Program Clarification Act exempts certain creditors from Red Flag Rules." Privacy Alert, Hogan Lovells, 25 January 2011

Christopher Wolf, Timothy P. Tobin

On 18 December 2010, the Red Flag Program Clarification Act of 2010 (RFPCA) was signed into law by President Obama.1 The RFPCA aims to narrow the universe of "creditors" that must comply with the Fair Credit Reporting Act (FCRA) Identity Theft Red Flags Rules, which require the maintenance of a written Identity Theft Prevention Program.

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