Proven Solutions for Safer Schools and Workplaces

Red Flags Rule (Identity Theft) Compliance

At the request of Members of Congress, the Federal Trade Commission delayed enforcement of the "Red Flags" Rule until December 31, 2010, for financial institutions and creditors subject to enforcement by the FTC. The Rule was promulgated under the Fair and Accurate Credit Transactions Act (FACTA), in which Congress directed the Commission and other agencies to develop regulations requiring "creditors" and "financial institutions" to address the risk of identity theft. The resulting Red Flags Rule requires all such entities that have "covered accounts" to develop and implement written identity theft prevention programs to help identify, detect, and respond to patterns, practices, or specific activities - known as "red flags" - that could indicate identity theft.  NCHERM Group Partner Saunie Schuster has developed a comprehensive Red Flags Rule compliance audit for colleges and universities subject to the Rule.  This consultation can be adjusted to fit your institution's individual needs, and is available in half-day, one-day and multi-day lengths.

TNG has contracted with R. Eugene Schuster, President of Synerg~Ed, a technology and enrollment services consulting firm, to partner with us on the Red Flags Project.  Mr. Schuster, a former president of the American Association of College and University Registrar and Admissions Officers, retired from the CIO's office at The Ohio State University. He has over 30 years experience in higher education systems administration and development. View a detailed sample outline of this audit.  PDF

What clients are saying about our work on Red Flags:

Saunie and Gene are very knowledgeable and approachable.  The scenarios were helpful and the "red flag documentation" activity at the end gave us the opportunity to talk about what we were doing right and what we need to improve upon.  I think the feedback from the sessions that Saunie is bringing back is critical for an effective program.

~ Sharon Mills, Dean of Administration

Community College of Allegheny County-South Campus

For more information, contact Kate Halligan, Vice President of Client Relations at or (610) 579-3725.