FINRA Provides Template for Complying with FTC’s Identity Theft Rule
FINRA has developed and provided a template policies and procedures document for complying with the FTC’s “Red Flags Rule,” which requires firms to create a written Identity Theft Prevention Program. FINRA cautions firms to tailor the template to their particular businesses.
OUR TAKE: Use the template and tailor it to your business. FINRA would rather see their template than try to determine whether some other form fits the rule. We would also recommend use of the template as an industry standard for firms required to implement an ITPP but are not FINRA members.