Foley proudly presents our new Web conference series focused on the most pressing legal and business issues for the vacation ownership and timeshare industry. In each session, members of Foley’s Hospitality, Resort & Golf Industry Team and leading executives will explore the latest developments, their impact on your business, and practical strategies to help you stay ahead in our dynamic industry.
In the first session of Timely Insight, Foley Partner Dan Bachrach moderated a discussion regarding Compliance With the Red Flags Rules between Foley Partner Andrew B. Serwin and Marriott International, Inc. Vice President and Senior Counsel Douglas Kelly.
Business owners and operators may not be aware that the FTC’s Fair and Accurate Credit Transactions Act of 2003 (FACTA) creates requirements for creditors to develop and implement identity-theft prevention programs. While these so-called Red Flags Rules seem to be directed at financial institutions, the rules define “creditor” as “any person or business who arranges for the extension, renewal, or continuation of credit” with a “covered account.” Intentionally or not, this broad definition describes many businesses outside of the financial industry, including developers, lenders, and operators of resorts. Although the FTC recently delayed enforcement of the Red Flags Rules until November 1, 2009, there are actions you should consider taking now to prepare for the upcoming compliance requirements.
This Web conference explored the following topics:
- Understanding what Red Flags Rules require
- Implications for companies under other laws
- First-hand experience from an insider’s perspective
- Tips for conducting risk assessments
For additional information about Timely Insight: The Vacation Ownership Industry Web Series, please contact Jackie Polson at jpolson foley.com.