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Day Pitney senior counsel and Compliance Risk Services director Jim Bowers is quoted in an April 23 Law360 article on the Security and Exchange Commission's recently finalized rules regarding identity theft programs. In the article Jim says that, "It's not just a matter of finding a model program on the shelf and adapting that to a particular entity." He continues, "That approach is doomed to fail because you missed the mark. In order to develop an effective program, it needs to be preceded by an analysis of the risk to the secure maintenance of confidential information."