GLBA Compliance & Risk Assessment Services
What Does GLBA Require?
The FTC Safeguards Rule: Nine Required Elements
Under the FTC’s amended Safeguards Rule (16 CFR Part 314), a covered institution’s written information security program must include nine specific elements. These requirements have been fully enforceable since June 9, 2023, with breach notification obligations following in May 2024.
A compliant program must designate a Qualified Individual responsible for overseeing and enforcing the security program. It must base safeguards on a written risk assessment that identifies internal and external threats to customer information and evaluates the sufficiency of existing controls. From that assessment, the institution must design and implement specific technical safeguards, conduct regular testing of those safeguards, train its workforce, oversee its service providers, keep the program current as risks evolve, maintain a written incident response plan, and require the Qualified Individual to report regularly to the board or senior leadership.
The Eight Required Safeguards
The risk assessment drives a set of specific technical and administrative controls. At a high level, these include access controls, an asset inventory, encryption of customer information, secure application development practices, multi-factor authentication, secure data disposal, change management, and monitoring of user activity.
Encryption applies to customer information both at rest and in transit, and multi-factor authentication is required for anyone accessing systems that hold customer data.
Risk Assessments and Penetration Testing
Two requirements sit at the center of demonstrating a working program: the risk assessment and ongoing security testing. The written risk assessment is the foundation. It is not a one-time exercise. The Safeguards Rule requires ongoing risk assessments, safeguard testing, vendor oversight, board reporting, and program updates rather than a single project that is finished once and filed away.
For testing specifically, the Rule sets a clear standard. Covered non-bank financial institutions must conduct annual penetration testing and semi-annual vulnerability assessments, or implement continuous monitoring that achieves comparable outcomes. This is one of the most concrete and frequently overlooked obligations, and it is where many institutions discover gaps between their documented program and their actual security posture.
Who Needs GLBA Risk Assessments?
The Safeguards Rule applies broadly. It covers any entity the FTC treats as a “financial institution” under GLBA, a definition that reaches well beyond banks to include mortgage lenders, auto dealers, tax preparers, investment advisers, and Title IV higher education institutions handling federal student aid data. The consequences of falling short are significant. Civil penalties currently exceed $50,000 per violation, and individual officers and directors can face fines of up to $10,000 per violation and up to five years of imprisonment for willful violations.
Our services cater to all entities classified as “financial institutions” under the GLBA and FTC Safeguards Rule, including:
Banks and credit unions
Mortgage lenders and brokers
Payday lenders
Finance companies
Insurance companies
Tax preparation firms
Higher education institutions providing financial aid
Finders (entities that bring together buyers and sellers of financial products)
Our GLBA risk assessment process aligns with GLBA 501(b) and FTC requirements, ensuring a thorough evaluation of your information security practices. Here’s an overview of our step-by-step approach:
Create a comprehensive inventory of all data assets containing customer information (Logical and physical assets).
Map data flows within your organization.
Identify internal and external threats to the security of customer information.
Assess the likelihood and potential impact of identified threats.
Consider various threat vectors, including cybersecurity risks, physical security, and insider threats.
Determine throughout review of vulnerability reports, current vulnerabilities that exist or perform scans of assets in scope to determine vulnerabilities (if need be).
Identify weaknesses in your current security controls.
Evaluate the potential for unauthorized access, use, or disclosure of customer information.
Evaluate and categorize identified security risks or threats.
Assess the confidentiality, integrity, and availability of your information systems.
Determine the adequacy of existing controls in the context of identified risks.
Control Evaluation and Implementation.
Review existing safeguards and their effectiveness in mitigating identified risks.
Recommend additional controls or improvements to address gaps.
Assist in implementing new safeguards, including administrative, technical, and physical measures.
Prepare a detailed risk assessment report.
Document findings, recommendations, and action plans.
Provide executive summaries for board members and senior management.
Include management responses.
Establish processes for ongoing risk monitoring.
Conduct periodic reassessments to identify new threats or vulnerabilities.
Consider various threat vectors, including cybersecurity risks, physical security, and insider threats.
Create a comprehensive inventory of all data assets containing customer information (Logical and physical assets).
Map data flows within your organization.
Identify internal and external threats to the security of customer information.
Assess the likelihood and potential impact of identified threats.
Consider various threat vectors, including cybersecurity risks, physical security, and insider threats.
Determine throughout review of vulnerability reports, current vulnerabilities that exist or perform scans of assets in scope to determine vulnerabilities (if need be).
Identify weaknesses in your current security controls.
Evaluate the potential for unauthorized access, use, or disclosure of customer information.
Evaluate and categorize identified security risks or threats.
Assess the confidentiality, integrity, and availability of your information systems.
Determine the adequacy of existing controls in the context of identified risks.
Control Evaluation and Implementation.
Review existing safeguards and their effectiveness in mitigating identified risks.
Recommend additional controls or improvements to address gaps.
Assist in implementing new safeguards, including administrative, technical, and physical measures.
Prepare a detailed risk assessment report.
Document findings, recommendations, and action plans.
Provide executive summaries for board members and senior management.
Include management responses.
Establish processes for ongoing risk monitoring.
Conduct periodic reassessments to identify new threats or vulnerabilities.
Update the risk assessment based on changes in your business environment or regulatory requirements.
Benefits of Our GLBA Risk Assessment Services
By partnering with us for your GLBA risk assessment needs, you’ll gain a comprehensive understanding of your organization’s security landscape and a clear roadmap for maintaining compliance and protecting sensitive customer information.
Ensure compliance with GLBA and FTC Safeguards Rule requirements
Identify and address potential security gaps before they lead to breaches
Demonstrate due diligence to regulators and stakeholders
Enhance overall cybersecurity posture and protect customer trust
Receive expert guidance on implementing cost-effective security controls
Meeting these requirements in 2026 takes more than a policy document. Elevate Consult helps financial institutions build and validate a defensible Safeguards Rule program end to end: conducting the written risk assessment, performing the annual penetration testing and semi-annual vulnerability assessments the Rule requires, implementing the eight technical safeguards, and establishing the vendor oversight and incident response processes that hold up under FTC scrutiny. Schedule a GLBA compliance consultation to assess where your program stands and what it takes to close the gaps.