FTC Safeguards Rule – Part 3:   Effective Date December 9, 2022

What is required under the Safeguard rules?

The FTC requirement under the Safeguards Rule is that each company have an Information Security Program.

This is designed to protect personal customer information collected during the lending process. (Definition of a customer in Blog part 2).

The definition of customer information from the FTC

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.