If we buy papers or contracts from dealers, and the dealers dont do any transactions or take any payments, Do we as a Financial Institution have to require the Dealers to have a written Red Flag policy and procedure? Then, once we buy the contract, our red flag policies and procedures apply, right? Any help is appreciated! Thanks.

The dealers are creditors and are covered by the regulations. I would think your contract already requires them to comply with laws and regulations. However, you may want to confirm what they are doing.