GLBA Safeguards & Privacy Rule compliance, audited and documented.
The Gramm-Leach-Bliley Act (GLBA) governs how US financial institutions handle non-public personal information (NPI). The 2023 Safeguards Rule update mandates nine specific cybersecurity controls including MFA, encryption, access controls, vulnerability scanning, and incident response. GR IT Services runs GLBA-readiness assessments, closes the gaps, and prepares examiner-ready evidence packages.
- 9 controlsSafeguards Rule
- 36 hoursBreach notice SLA
- CISOQualified Individual
- OCC/FRB/FDICExaminer-ready
Nine capabilities for GLBA Safeguards compliance.
Qualified Individual designation
Appoint and document a Qualified Individual (typically the CISO or equivalent) responsible for overseeing the information security programme. Annual reporting to the Board required.
Written Information Security Programme (WISP)
Author or update the WISP covering risk assessment, control implementation, vendor management, employee training, and incident response. The cornerstone document of GLBA compliance.
Risk assessment & control mapping
Periodic risk assessments identifying foreseeable internal and external threats to NPI. Map controls (technical, administrative, physical) to each identified risk. Documented and reviewed annually.
Access controls & MFA enforcement
Multi-factor authentication on every system handling NPI. Role-based access control with least-privilege design. Quarterly access reviews. Privileged-access management for sysadmins.
Encryption (at rest & in transit)
NPI encrypted at rest using FIPS 140-validated cryptography, encrypted in transit over TLS 1.2+. Customer-managed keys for cloud workloads. Mobile-device encryption enforced via Intune.
Vulnerability scanning & pen testing
Continuous vulnerability scanning of all in-scope systems plus annual penetration test by an independent provider. Findings tracked through remediation in a written POAM.
Vendor & service-provider oversight
Vendor due-diligence at onboarding, contractual safeguards, ongoing monitoring. Many GLBA breaches originate at vendors — this is one of the controls examiners probe hardest.
Incident response & breach notification
Written IR plan, tabletop exercises, on-call rotation. Crucially: 36-hour FTC breach-notice workflow following the 2024 amendment, plus 30-day customer notification SLA where required.
Privacy Rule disclosures
Annual privacy notice, opt-out mechanisms for information sharing, and Privacy Rule consumer disclosures. Aligned with state law overlays (NYDFS Part 500, CCPA) where applicable.
Four reasons US financial institutions pick us.
NYDFS Part 500 overlap
New York financial institutions face NYDFS Part 500 alongside GLBA. Most controls overlap; we run both audits in a single engagement with one evidence pack.
Microsoft 365 + Defender baselines
GLBA controls map cleanly onto Microsoft 365 E5 + Defender suite + Entra Premium P2. Our typical engagement deploys these baselines once and produces examiner-ready evidence indefinitely.
US delivery, regulator-fluent
Engagements across the US financial-services corridor (NYC, Boston, Charlotte, Chicago, DFW, SF). Familiarity with OCC, FRB, FDIC, NCUA, FTC, and state regulator examination styles.
Evidence pack is the deliverable
We do not stop at "controls implemented". We deliver the binder: WISP, risk assessments, access-review records, training logs, incident-response history, vendor reviews. Hand it to the examiner unedited.
GLBA engagements across US financial services.
Community & regional banks
State and federally chartered community banks under FDIC, OCC, or FRB examination. Typical scope: 100-1,500 employees, core banking + treasury + commercial lending.
Broker-dealers & RIAs
SEC-registered broker-dealers and registered investment advisers. GLBA overlaps with Reg S-P; we run both with the same control implementations.
Credit unions
NCUA-examined credit unions facing GLBA Safeguards Rule under FTC enforcement authority where they cross NCUA thresholds. Often paired with NCUA-specific cybersecurity exam guidance.
Hedge funds, family offices, private equity
Investment management firms subject to SEC Reg S-P or state-level financial-privacy law. GLBA-derived obligations apply via FTC and state attorneys-general.
Insurance carriers & brokerages
State-regulated insurance carriers under NAIC Model Law (which mirrors GLBA Safeguards). Property/casualty, life, and specialty lines.
Mortgage originators & non-bank lenders
Independent mortgage banks, marketplace lenders, BNPL providers, and consumer-credit fintechs that hit FTC GLBA enforcement scope. The 2023 Safeguards update specifically expanded coverage here.
How GLBA compares to NYDFS Part 500 and SEC Reg S-P.
| Feature | GLBA Safeguards FTC / federal banking regs | NYDFS Part 500 NYC-licensed financial entities | SEC Reg S-P Broker-dealers, RIAs |
|---|---|---|---|
Applies to | All financial institutions under GLBA | NY DFS-licensed entities | SEC-registered B/D and RIA |
Written security programme required | |||
MFA mandatory | Yes (2023 update) | Yes | Effectively (Reg S-P 2024 amendment) |
Encryption mandatory | Yes | Yes | Yes |
Board / governance reporting | Annual to Board | Annual CISO + Board cert | Annual to senior management |
Breach-notice timeline | 36 hours to FTC | 72 hours to NYDFS | 30 days to customers (2024) |
Third-party / vendor oversight | |||
Vulnerability scanning + pen test | Annual pen test required | Annual pen test required | Risk-based |
Readiness to examiner-ready in four phases.
- 1
Risk assessment & gap analysis
4-6 weeks
Document where NPI lives, who accesses it, and how. Map current controls against the nine Safeguards Rule requirements. Output: written risk assessment, gap report, and remediation plan.
- 2
WISP authorship & policy build
4-6 weeks
Author or update the Written Information Security Programme. Develop sub-policies (acceptable use, access control, encryption, incident response, vendor management, training). Board review and approval.
- 3
Technical remediation
3-6 months
MFA rollout, encryption deployment, vulnerability-scanning programme, SIEM stand-up, privileged-access controls, mobile-device management, vendor-monitoring tooling.
- 4
Examiner-ready evidence & ongoing
Continuous
Compile the evidence binder, run a mock examination, train executives and the board on what examiners ask. Then ongoing: monthly continuous-monitoring, quarterly access reviews, annual pen test, annual risk reassessment.
“Our last OCC exam flagged six findings against the Safeguards Rule — most around access controls and vendor management. GR IT scoped the remediation, deployed Microsoft Defender plus Entra conditional access on the back end, and built the WISP and vendor-management programme in writing. Our next exam closed clean with no MRAs.”
GLBA Safeguards Rule, frequently asked.
Financial-services compliance resources.
Cybersecurity audit & compliance services
General-purpose audit pillar covering HIPAA, SOC 2, NIST CSF, ISO 27001, PCI DSS.
Learn moreMicrosoft Defender for financial services
Defender suite tuned for financial-services threat profile (executive impersonation, wire-fraud campaigns).
Learn moreMicrosoft Entra ID (Azure AD)
Identity-and-access-management foundation for MFA, conditional access, and Safeguards Rule access-control requirements.
Learn moreBook a GLBA readiness review.
Sixty-minute discovery call with a senior consultant. Output: a written first-cut gap estimate against the nine Safeguards Rule controls. No obligation.