On December 31, 2010, the Federal Trade Commission (FTC) began enforcement of the Red Flags Rule. The memo provides guidance for manufactured home land-lease communities and retailers on how to comply. The Manufactured Housing Institute (MHI) discussed issues related to communities and retailers with FTC staff and believes that the information contained in the memo reflects how communities and retailers are impacted by the Red Flags Rule. However, the policies developed by MHI members should be reflective of their specific business needs and practices, and should involve legal counsel.


FTC Red Flags Rule The Federal Trade Commission (FTC) has issued regulations requiring financial institutes to develop and implement written identity theft prevention programs as part of the Fair and Accurate Credit Transactions (FACT) Act of 2003. Programs must be in place by December 31, 2010. The FTC has developed a downloadable template for businesses that are low-risk for identity theft. MHI has included suggested wording in the “Here are reasons we are at low risk for identity theft” section of the form. However, this form should be modified to fit individual business needs. The do-it-yourself template is available by clicking here MHI has also developed a template that can assist businesses wanting to develop a more customized Red Flags program. It is available by clicking here. Click here for the FTC guide, Fighting Fraud with the Red Flags Rule: A How-To-Guide for Business. On pages 19-21 you will find the common “Red Flags” that are part of Step 1 of the do-it-yourself template above which requires you to identify “Red Flags” that are relevant to your business. Click here to view the FTC’s “How To Guide for Business.