As a reminder, the Identity Theft Red Flags Rules jointly adopted by the SEC and CFTC, which took effect on May 20, 2013, have an upcoming compliance date of November 20, 2013.  Under these rules, certain SEC and CFTC-regulated entities—including registered investment advisers, commodity trading advisors and commodity pool operators—that qualify as “financial institutions” or “creditors” and offer or maintain “covered accounts” must establish programs to address risks of identity theft.

For a summary of the new Identity Theft Red Flags Rules, see our May 28, 2013 Foley Adviser.