In accordance with Federal Trade Commission’s (FTC) “red flag” rules of the Fair and Accurate Credit Transactions Act (FACTA) of 2003, the Washington Suburban Sanitary Commission (“WSSC” or “Commission”) is required to implement and maintain an identity theft prevention program (the “program”). The Act applies to financial institutions and creditors with covered accounts. The Commission under this rule (see WSSC 10.20.020, Definitions) has covered accounts and is a creditor and must comply with FACTA and its associated regulations. (GMO 09-01)