The Federal Trade Commission has a delightful new rule, the Red Flags Rule (link is to a 17 page .pdf from the FTC), which may draw your nonprofit into its regulatory web.
Your involuntary participation hinges on the law’s definition of “creditor” and the Red Flags Rule clearly announces that charities can fall within the law’s reach. This has me thinking about red flag football as a kid, when I was routinely forced into involuntary non-participation, after neither team picked me as a player. In an especially low point in my childhood, I was the football.
The Red Flags Rule compels organizations of all types to identify those business processes (red flags) that make them vulnerable to identity theft. Enforcement begins in December of this year.