GLBA Safeguards Rule Compliance Advisory
The applicability question. The written risk assessment. The program that actually meets the 2023 requirements.
GLBA Safeguards Rule compliance advisory for non-bank financial institutions — mortgage brokers, auto dealers who finance, tax preparers, and more — from someone who builds this exact program (risk assessment, access controls, encryption, incident response, vendor oversight) across HIPAA, SOC 2, and ISO 27001 engagements every day.
Schedule a Free ConsultationThe GLBA Challenge
Most people associate GLBA with banks. That's the wrong mental model. The FTC's definition of "financial institution" is broader than the banking definition — it covers a lot of ordinary small businesses that have no idea they're regulated under it at all.
And if you haven't looked at your Safeguards Rule compliance since before June 2023, you're working from the old version of the rule. The update made "reasonable safeguards" specific: MFA, encryption, annual penetration testing, a named accountable person, and an annual report to your board — requirements many small businesses have never heard of, let alone implemented.
What We Deliver
A program that meets the FTC's 2023 Safeguards Rule requirements — not a checklist copied from a generic template.
- Applicability review — do you actually count as a "financial institution" under GLBA
- Required written risk assessment (per 16 CFR § 314.4(b))
- Qualified Individual designation and program oversight
- Gap assessment against every 2023 Safeguards Rule requirement
- Access control, encryption, and MFA implementation guidance
- Written incident response plan
- Service provider / vendor oversight program
- Annual board (or senior officer) report preparation
What the 2023 Rule Specifically Requires
- •Named Qualified Individual, reporting to the board annually
- •Written risk assessment, specific to your business
- •Encryption at rest and in transit — no longer optional
- •MFA on any system touching customer information
- •Annual penetration testing, vulnerability assessments every 6 months
Our Process
From the applicability question through a program you can actually maintain year over year.
Applicability & Scoping
Confirm whether GLBA actually applies, what counts as "customer information" in your business, and whether the small-business exemption changes anything.
Risk Assessment
A written risk assessment specific to your operation — not a template — per the Rule's own required format.
Gap Remediation Plan
Compare current state against every 2023 requirement; prioritized fixes with ownership and timelines.
Ongoing Compliance
Annual board reporting, periodic reassessment, and vendor oversight cadence going forward.
Who This Is For
If your business handles customer financial information — even if you'd never describe yourself as a "financial institution" — this likely applies to you.
- Mortgage brokers and non-bank lenders
- Auto dealers who arrange or offer financing
- Tax preparers and accountants who prepare returns
- Insurance agents and agencies
- Retailers that issue store credit or offer in-house financing
- Non-SEC-regulated financial and investment advisors
- Debt collectors and check-cashing businesses
The Same Program, Applied to a New Rule
Jonathan Carpenter brings 25+ years of security program experience — the same risk assessment methodology, access control design, encryption and MFA implementation, and incident response planning that HIPAA, SOC 2, and ISO 27001 engagements are built on — applied specifically to the Safeguards Rule's 2023 requirements. The elements the FTC requires aren't new territory; they're the same program components built repeatedly under other frameworks, with GLBA's own citations attached.
Every control referenced in this engagement traces to the actual text of 16 CFR § 314.4 — not a secondary summary or a generic template — the same primary-source standard applied across Anchor's Compliance Framework Crosswalk tool.
25+ Years Enterprise Security Experience
- →Same program-build methodology already applied across HIPAA, SOC 2, and ISO 27001 engagements
- →Risk assessment, access control, encryption, and incident response planning — the actual program elements the Rule requires
- →Every control traced to the actual 16 CFR § 314.4 text, not assumed from a template
Related Services & Resources
GRC & Compliance Advisory
Broader compliance program management across multiple frameworks.
vCISO Services
Fractional CISO — ongoing security leadership for your business.
Security Assessments
Risk assessments, vulnerability analysis, and security program gap analysis.
Compliance Framework Crosswalk
See every GLBA Safeguards Rule element mapped against CSF, ISO 27001, HIPAA, and more — free.
Not sure if GLBA applies to your business?
Schedule a free consultation. We'll walk through whether you're covered and what a Safeguards Rule program would actually involve for your operation.
Schedule a Free Consultation