This is a Red Flag policy developed by Sumitomo Electric Lightwave Corporation in response to the FTC's pending "Red Flag" legislation. It is an excellent template to build from - both concise and thorough.

As with all such policies, it is very important that you consider this a starting point and perhaps an “idea-generator” for your own operations. It’s possible that this will fit right in. But it’s likely that you’ll need to make some modifications to this to make it a perfect fit. We have highlighted in yellow the areas that (at a minimum) you’ll want to change for your firm.

Good luck!