The Federal Trade Commission (FTC) will begin enforcement of the Red Flags Rule on December 31, 2010.  The FTC issued regulations (the Red Flags Rule) on November 9, 2007 requiring financial institutions and creditors to develop and implement written identity theft prevention programs as part of the Fair and Accurate Credit Transactions (FACT) Act of 2003. In addition, the rule implements Section 315 of the FACT Act, which applies to users of credit reports. This section specifically includes “landlords” or land-lease communities, and requires users of consumer reports from credit bureaus to develop reasonable policies and procedures to determine the identity of an applicant when a “notice of address discrepancy” from a consumer reporting agency is received. More information is available from the Manufactured Housing Institute (MHI) at http://www.manufacturedhousing.org/lib/showtemp_detail.asp?id=374&cat=retailer. See also Ken Rishel’s November Feature Article, http://www.mhmsm.com/featured-articles/november-2010/1189-red-flag-compliance