Fair Credit Reporting: 9.2.7.2.2 Scope: Application to “creditors”
In a guidance document interpreting these regulations, the FTC indicated that the red flag guidelines requirement applied not only to lenders, but other entities who could be considered “creditors” under the Equal Credit Opportunity Act (ECOA)288 including “professionals, such as lawyers or health care providers, who bill their clients after services are rendered.”289 Legislators became concerned that these businesses would be overburdened by the requirement to have red flag guidelines.