applying the rule to lawyers is «arbitrary, capricious and contrary to law,» and that the FTC has failed to «articulate, among other things: a
rational connection between the
practice of law and identity theft; an explanation of how the
manner in which lawyers bill their clients can be considered an extension of credit under the [Fair and Accurate Credit Transaction Act]; or any legally supportable basis for application of the Red Flag Rule to lawyers engaged
in the
practice of law.»