The identity theft prevention program (“program”) was developed pursuant to the Federal Trade Commission’s Red Flags Rules (“Rules”), which implement § 114 of the Fair and Accurate Credit Transactions Act of 2003, 16 C.F.R. § 681.2, being 15 U.S.C. § 1681m(e).
(Res. 09-R-1, passed 4-21-2009)