FTC Safeguards Rules – Part 2: Effective Date December 9, 2022
Whose information is being safeguarded?
The regulations detail all of the different customer relationships, but it comes back to the same thing, in my opinion.
If at any point in a financial transaction, you have access to the borrower’s PII, that would be a customer.
What customer information is being safeguarded?
This is fairly obvious, but here is the definition.
Customer information means any record containing nonpublic personal information about a customer of a financial institution, whether in paper, electronic, or other form, that is handled or maintained by or on behalf of you or your affiliates.
Nonpublic personal information means: (i) Personally identifiable financial information; and (ii) Any list, description, or other grouping of consumers (and publicly available information pertaining to them) that is derived using any personally identifiable financial information that is not publicly available
Storage of this information will be covered in future blog posts