Red Flags and Address Discrepancies FAQs : Privacy Law Blog. Good post here about the FTC "Red Flag" rules. Financial institutions are "covered entities" BUT what many eCommerce websites don't realize is that they are potentially covered entities as well. Why? For software-as-a-service site (SaaS) sites it may depend on whether they allow customers to make monthly or quarterly installment payments on the subscription price. If so, they may be considered a "creditor" under the rules. Ouuch. Most eCommerce sites probably have no idea that they might some liability under FACTA.
Privacy and data security continue to be hot topics and you can expect the FTC to become more aggressive in its enforcement activities.
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