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Stay Red Flag Compliant: Identity Theft Prevention and Affiliate Marketing Requirements Under FACTA

OnDemand Webinar (57 minutes)

Learn more about identity theft prevention and how to stay compliant with affiliate marketing under FACTA.The Fair and Accurate Credit Transaction Act (FACTA) amended the Fair Credit Reporting Act to direct the FTC and other federal agencies to establish requirements for financial institutions to establish reasonable policies and procedures to prevent identity theft. FACTA also establishes special and complex rules related to sharing information with affiliates for marketing purposes. The FTC and other regulators actively enforce these requirements. This topic will provide an overview of these requirements with practical compliance tips to help ensure your program is up to speed.


Donnelly L. McDowell, Kelley Drye & Warren LLP


Identity Theft Prevention

• Who Has to Develop a Red Flag Compliance Program?

• What Are These Red Flags?

• How Have the Requirements Evolved?

Affiliate Marketing

• What Counts as an Affiliate?

• What Are the Notice and Opt-out Requirements?

• Methods of Notice

Red Flag Compliance Programs

• Where to Begin: Who Are Your Primary Users, Providers, and Maintainers of Information?

• Building a System That Detects, Prevents, and Responds to Identity Theft

• Making It All Work in Reality