On October 22, 2008, the Federal Trade Commission issued a press release
notifying organizations that it had granted a six-month delay of enforcement regarding the FACT (Fair and Accurate Credit Transactions) Act's Red Flag Rules. The Red Flag rules previously had a November 1, 2008 required implementation date. Due to some confusion and uncertainty on the part of several industries about the applicability of these rules to their organizations, the FTC has postponed enforcement action for violation of the Identify Theft Red Flags until May 1, 2009. As many of you already know, the FTC has taken the position that the FACT Act applies to municipal utility systems.