2008 Compliance Insurance Retail 
Hunton Privacy
FEBRUARY 20, 2009
CVS Pharmacy (“CVS”), reportedly the largest retail pharmacy chain, has agreed to pay the Department of Health and Human Services (“HHS”) $2.25 CVS Pharmacy (“CVS”), reportedly the largest retail pharmacy chain, has agreed to pay the Department of Health and Human Services (“HHS”) $2.25
Hunton Privacy
APRIL 3, 2009
For entities subject to the FTC’s jurisdiction, the relevant compliance deadline is May 1, 2009. Financial institutions that are regulated by federal bank regulatory agencies or the National Credit Union Administration (which issues their own versions of the Red Flags Rule) were required to comply with the Rule as of November 1, 2008.
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