How do I know if Im a Creditor as defined by the Red Flags Rule?
You are a creditor if you offer credit facilities to your customers. For example, if you offer a branded credit card or in-house financing, you are a creditor. You may also be a creditor if you deliver your product first, and allow customers to pay all or part of the purchase price later through memo transactions and other installment payment plans. Congress is currently considering legislation which, if passed, will exclude from the definition of creditor those companies that know all their customers or have not experienced identity theft. Remember, though, just because you are a creditor does not mean that you need a Red flags Program. That depends on whether or not you have covered accounts.
