Dodd-Frank transferred responsibility for identity theft from the FTC to the CFTC and SEC for those financial institutions under their jurisdiction. The rules adopted in April 2013 require “financial institutions” that “hold” “covered accounts” to establish an Identity Theft Prevention Program (“ITPP”). These rules are known as the “Red Flag” rules. The CFTC has defined the term “financial institution” to include FCMs, IBs, CTAs and CPOs as well as Swap Dealers. Traditional futures trading accounts are considered “covered accounts”. If you don’t “hold”, covered accounts, directly or indirectly, then the extent of your responsibility under the Red Flag rules is…