81f2a14e_te_Legal_Forms___SaaS_Contract__Description
[Website Legal Form] Website Red Flag Identity Theft Policy [Comments] “Financial institutions” include banks, savings and loans, and credit unions You would be a “creditor” dealing in “covered accounts” if: (i) you extend credit by agreeing to receive payment over time (however, if your customer pays upon receipt of the product or service, even if with a credit card, you are probably not a “creditor” dealing in “covered accounts”); (ii) however, there is an EXCLUSION provided the Red Flag Program Clarification Act of 2010 if you “advance funds on behalf of a person for expenses incidental to a service provided by the creditor to that person” – this EXCUSION means that you would not be a creditor if you extend credit to purchasers of your services – for example, the EXCLUSION would apply to healthcare providers, law firms, and accounting firms. [Description] 
For compliance with the U.S Fair Credit Reporting Act, as amended by the Fair and Accurate Credit Transactions Act of 2003 (FACTA), which requires “financial institutions” and "creditors" with "covered accounts" to adopt and implement an identity theft policy and program by May 1, 2009 Failure to comply may result in civil lawsuits by consumers for actual damages — and if actual damages can’t be proved, nominal damages Civil litigants may also recover punitive damages and attorney’s fees. In addition, the FTC may initiate administrative proceedings
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