Business Round Table

I promised to keep you up to date on the Red Flag Rule

by Cheryl Baumgartner Medical Billing/Coding/Insurance
Cheryl Baumgartner Professional Premium   Medical...
Okay we've been doing a lot of studying and research on the Red Flag Rule or at least  my company has.  They have just released information on who is covered by the Red Flag.

All financial institutions as defined under Gramm Leach Bliley that is you are significantly involved in financial products or services.

But here is the biggie all creditors.
Under FACTA all creditors is defined as anyone who accepts a deferred payment.  Deferred payment is basically anything other than cash.  Checks and credit cards are deferred payments so that places you in the category of a creditor.  It also means that just about anyone who is doing business is covered.

You also cannot escape liability by outsourcing.  So if you decide to hire a third party to handle your payment processing you still have liability.
Feb 19th 2008 14:20

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