Ask CCRM: Do You Need to Comply with the Red Flags Rule?

July 26, 2013 | Aging Services Risk Management


A Continuing Care Risk Management (CCRM) member recently asked how to determine whether the organization is a “creditor” as defined by the Red Flags Rule and therefore must comply with the rule.

The law was changed on December 18, 2010, to more narrowly limit who is a creditor. However, the Federal Trade Commission (FTC) is quite clear that there are no industry-wide or sector-wide exemptions. Rather, whether the organization is a creditor...

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