If it feels like you've been here before, that's because you have.  Three times before, to be exact.  On October 30, 2009, the FTC announced that at the request of Members of Congress it has once again delayed the enforcement of the identity theft "Red Flag" rules.  After the previous delay, the rules were set to take effect on November 1.  This newest delay will move the enforcement date to June 1, 2010.  As we have indicated in previous eBulletins, the Red Flag rules apply to "financial institutions" and "creditors."  Early on the FTC took a very broad view of the term "creditor," maintaining that it includes businesses that fail to demand payment at the time services were rendered or goods were sold.  According to the FTC, this includes, among others, physicians and attorneys.  However, in the face of pending legislation that would scale back the scope of the rules and a Federal court decision holding that the rules do not apply to attorneys, the FTC has announced a new delay.  We will continue to keep you informed about new developments regarding the application and enforcement of these rules.  In the mean time, feel free to contact us with any questions you may have.