Red Flag Rule
DEQ fee increases & Red Flag Rule
|Application to Municipal Attorney’s in Private Practice|
One of the most interesting applications of the Red Flag Rules to municipal operations is whether the Rule applies to an attorney in private practice.
Red Flag Rules and Guidelines
FTC confirms that municipalities are subject to the Red Flag rules for all utility operations and other services for which payment is deferred for multiple transactions. Look for news of training events being developed by OML.
See the FTC powerpoint and the Final Rule beginning at page 63771. The rule contains Guidelines (see Rule at pages 63773 -63774 and the Powerpoint at pages 14-26). It also includes 26 examples of red flags (see Rule at page 63774 and the Powerpoint at pages 27-28).
Final Rules (.pdf)
FTC PowerPoint (.ppt)
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