June 28, 2022
Good Morning,
There is a new sheriff in town! As you
know all too well, we already have many sheriffs. But this one
is actually an old sheriff with a new rule. In some cases, it
may even include state regulators enforcing a new rule. Read on.
While compliance may not be a pleasant
issue to spend time on, it is a must in our business. With a
little attention and support, it can be successfully managed.
INFORMATION SECURITY
The regulator, in this case, is
the Federal Trade Commission (FTC) and the
CFPB
(both), and the rule is called the Safeguards Rule.
For those who use our Compliance
Management System (CMS), we have an existing training course and
a detailed policy document called Information Security that
covers this topic. That policy is the prior version of the
Safeguards Rule, which has been around for many years. That rule
is a part of the Gramm-Leach-Bliley Act (GLBA).
Information Security is a stand-alone
section of that CFPB policy manual.
THE NEW RULE
The new version of the rule is orders of
magnitude more intense than the prior version. The rule covers
all aspects of information security. And it includes both IT
infrastructure and physical material security. The FTC and CFPB,
including some state regulators, are intently focused on
security, especially in consumer finance.
In fact, you should be as well.
Unfortunately, security breaches are pretty common and can be
devastating if you happen to be on the receiving end!
We have a group of attorneys at the
national top fifty law firm of
Troutman Pepper who have many years of direct experience
with this subject. That experience is with our industry and
includes working on this policy which is an integral part of our
CMS system. The attorneys recently moved over from Ballard Spahr,
as we noted
here.
WHAT IS
NEXT?
Our next email on this topic will provide
an overview of the impact of this rule on your company. Over the
coming days and weeks, we will post updates and webinars on this
new rule. Finally, we will address how you can implement this
rule in your company. We will also have a policy manual update
to our CMS manual and an updated online training course. Both of
these are required for your company to meet compliance
requirements.
In the meantime, if you have any questions
or comments, please drop us an email or call.
Thanks.
- Max
Questions or comments?
Email us at
info@borrowsmartcompliance.com
Direct Tel: 205-733-9926
