What the Mandate Requires
The 2023 amended FTC Safeguards Rule requires financial institutions to implement a comprehensive written information security program (WISP) that includes: a designated qualified individual overseeing the program, risk assessments, safeguards implementation, regular testing and monitoring, vendor oversight, an incident response plan, and annual reporting to the board of directors. Multi-factor authentication is now explicitly required for systems containing customer information.
| Statutory Reference | Requirement |
|---|---|
| 15 U.S.C. § 6801 | GLBA purpose — requiring financial institutions to protect security and confidentiality of customer records |
| 16 CFR Part 314 | Standards for Safeguarding Customer Information — the FTC Safeguards Rule (2023 amendment) |
| 16 CFR § 314.4 | Core elements of the required written information security program |
| 16 CFR § 314.5 | Safeguards applicable to specific categories of customer information |
| 16 CFR § 314.6 | Incident response plan and notification requirements for security events |
Enforcement Authority & Penalties
The FTC enforces GLBA and the Safeguards Rule. Civil penalties up to $51,744 per day per violation. State attorneys general may also enforce under parallel state financial privacy statutes. The FTC may seek injunctive relief, disgorgement, and civil monetary penalties for Safeguards Rule violations.
What VerdoCo Provides
Each document is delivered in both editable Word (.docx) format — with teal-bracketed fields for your organization's specific data — and a locked, forensically personalized PDF. Your organization's name, authorized representative, transaction ID, and canary reference code are injected into every page at the moment of purchase.
Establishes the foundational GLBA written information security program — the governing information security program policy, customer information inventory, FTC Safeguards Rule gap analysis against all required program elements, Safeguards Rule risk assessment, and multi-factor authentication assessment.
Delivers the operational GLBA compliance infrastructure — FTC examination readiness checklist, incident response plan, service provider oversight program, staff training matrix and completion log, and the required annual board-level report on the information security program.
Related Regulatory Series
Many organizations subject to VCO-GLBA also have obligations under the following frameworks. VerdoCo provides a complete series for each.
VCO-GLBA — Ready to Begin?
Select your phase or purchase the complete Command Kit. All documents delivered within minutes — personalized to your organization, forensically protected, and ready to complete.
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