On December 18, 2010, President Obama signed into law the Red Flag Program Clarification Act of 2010 to amend FCRA section 615(e). That section directs the federal banking agencies and the FTC to establish red-flag guidelines and regulations for use by financial institutions and creditors regarding identity theft. The new law clarifies that it only applies to “creditors” that pull credit reports, furnish information to credit bureaus or “advance funds” to borrowers. Although the purpose of the law was to exempt from the FTC’s red flags rule persons who are “creditors” solely because they bill in arrears, the amendment also exempts anyone who invoices customers for products and services. Retailers that handle credit card applications for a credit cardissuing bank, should now be exempt as well.