Required report on your Red Flags program

Answered by:

Question:

I want to be sure we are correctly handling the annual report that needs to be made on compliance with the Red Flags rule. Two questions: Does the report have to be made to the Board of Directors and what is the content of the report.

Answer:

First, remember that the report is to be made “at least annually.” In some circumstances, a more frequent report would be warranted. In terms of who to report to, the rule says it can be the board, an appropriate committee of the board, or a designated senior management employee. You will find guidance on what to include in the report in Appendix J to Regulation V.

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