The agent who sells us our professional liability insurance coverage sent me this last Wednesday:
On August 1, 2009, new federal regulations enforced by the FTC will go into effect; the so-called Red Flag rules, which require businesses, including lawyers and law firms, to take pro-active measures to detect and prevent identity theft. While implementation of these rules has now twice been postponed, (and some legal professional organizations are protesting their application to lawyers), it is important for lawyers to review them and plan for compliance. Although the FTC does not appear to specify final penalty amounts for non-compliance, it is clear that violators can be subject to significant civil penalties – making this information especially important for anyone who handles personal identity information of clients or customers.
Here is a link to the FTC website where the rules are discussed.