Kilpatrick Townsend

Revised Red Flags Rule

This week President Obama signed revised red flags rule legislation designed to exempt professionals and "other service providers" from the FTC Red Flags Rule.  It is unclear if this new legislation will change its application to health FSAs and HRAs that utilize debit cards.  The FTC website indicates that it is updating its guidance and will update the website when that process is complete.  In the interim, you can review the application of the Red Flags Rule for employee benefits, by reviewing our Legal Alert:  http://bit.ly/i5YOSm