As businesses increasingly rely on technology to store and maintain data, including customer records, the risk of identity theft also is increasing. The Federal Trade Commission ("FTC"), together with federal banking regulatory agencies and the National Credit Union Administration, has adopted new regulations intended to combat identity theft. Known as the Red Flag Rules, these new regulations require financial institutions and creditors to develop and implement a written identity theft prevention program to identify and combat identity theft in connection with new and existing customer accounts.

If you are an operator that provides service in advance of payment, then your company is a "creditor" because your company regularly extends, renews or continues credit or defers payment for goods or services.