Red Flag Rules and Compliance with the FACT Act

We think everyone understands that lending organizations must have a plan in place by November 1, 2008 to address the following: * Consumer creditors, whether they use consumer reports or not, must comply with the new Regulations because consumer creditors maintain "covered accounts" as that term is defined in the FTC Regulation. * Consumer creditors must establish an Identity Theft Prevention Program designed to detect, prevent and mitigate identity theft. * The Program, appropriate to the size and complexity of the creditor must: 1. identify relevant Red Flags for the types of accounts it maintains; 2. detect Red Flags that have been identified, when they occur; 3. respond appropriately to any Red Flags that are detected by it, to prevent and mitigate identity theft; 4. be updated by the creditor periodically. * The Program must be continually administered by the creditor including: 1. approval by the Board or a committee of the Board; 2. involve senior management; 3. staff training is required to effectively implement the Program, and; 4. oversight of service providers. Compass Technologies, in association with one of our strategic partners, is pleased to offer a 60 page comprehensive plan to address this compliance issue. Several clients have attempted to develop their own version of Red Flag compliance and found it to be time consuming and cost prohibitive. We have this document available now and can send to you to make part of your compliance records. We are offering this document (a $500 value) at no cost to all clients who sign up for a new product or service before November 1.