Compliance Framework

GLBA & FFIEC

Gramm-Leach-Bliley Act and Federal Financial Institutions Examination Council - The Regulatory Backbone of Financial Services Cybersecurity

GLBA (Gramm-Leach-Bliley Act) requires financial institutions to explain their information-sharing practices and protect sensitive customer data. The Safeguards Rule requires financial institutions to implement a comprehensive written information security program. FFIEC (Federal Financial Institutions Examination Council) provides the examination framework that federal and state regulators use to evaluate cybersecurity programs at banks, credit unions, and other financial institutions. Together, GLBA and FFIEC create the regulatory foundation for financial services cybersecurity. The FTC Safeguards Rule, updated in 2021 and effective 2023, expands GLBA requirements to a broader range of financial institutions, including mortgage brokers, auto dealers, tax preparers, and other non-bank financial entities.

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Key Requirements

GLBA & FFIEC Requirements

What you need to know about GLBA & FFIEC compliance. Need help getting started?

Develop, implement, and maintain a comprehensive written information security program (WISP) approved by the board or governing body
Designate a qualified individual (e.g., CISO) responsible for information security program oversight and implementation
Conduct periodic risk assessments that identify internal and external risks to customer information security, confidentiality, and integrity
Design and implement safeguards to control risks identified in risk assessments, including access controls, encryption, and monitoring
Oversee service providers to ensure they implement appropriate safeguards for customer information through contract requirements and assessment
Monitor, test, and update the information security program regularly, including penetration testing at least annually and vulnerability scanning at least quarterly
Establish incident response procedures that include incident detection, response, and notification to affected individuals and regulators
Require annual board or governing body reporting on the information security program including risk assessment results, testing, and incidents
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Related frameworks: HITRUST CSF · HIPAA · NIST CSF & NIST 800-171 · CMMC

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Why It Matters

Key Benefits

Why GLBA & FFIEC compliance matters for your business and how it protects your operations, customers, and growth.

Avoid regulatory enforcement actions, fines, and reputation damage from financial data breaches. State and federal regulators increasingly take enforcement actions against financial institutions with inadequate cybersecurity programs. Proactive compliance protects against regulatory sanctions.

Pass FFIEC examinations with documented, tested information security programs. FFIEC examinations assess cybersecurity across categories including risk management, access controls, data protection, and incident response. Organizations with mature programs face shorter examinations with fewer findings.

Protect customer financial data and build trust with account holders. Financial data is among the most targeted data by cyber criminals. Strong GLBA safeguards protect your customers and your relationship with them, reducing churn and strengthening your competitive position.

Reduce breach costs and regulatory penalties through documented compliance. The average cost of a data breach in financial services exceeds $5.7 million. GLBA-compliant security controls directly reduce breach risk, and documented compliance demonstrates good faith to regulators.

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Who It's For

Who Needs GLBA & FFIEC?

GLBA applies to financial institutions, defined broadly to include banks, credit unions, mortgage lenders, insurance companies, securities firms, and other businesses significantly engaged in financial activities. The FTC Safeguards Rule expands GLBA to include auto dealers, tax preparation services, check cashing businesses, credit counselors, financial advisors, collection agencies, appraisers, loan brokers, mortgage brokers, payday lenders, real estate settlement services, and other non-bank financial entities. FFIEC frameworks apply to federally regulated financial institutions including banks and credit unions.

How We Help

Our Approach to GLBA & FFIEC

We guide you through the entire compliance lifecycle. From gap analysis to audit support, we make compliance manageable.

01

GLBA compliance assessment including risk assessment development and WISP creation. We evaluate your current information security program against GLBA and FTC Safeguards Rule requirements, identify gaps, and deliver a comprehensive written information security program (WISP) tailored to your institution.

02

FFIEC examination preparation covering all categories of the FFIEC Information Technology Examination Handbook. We prepare your team for regulatory examinations with documented controls, evidence packages, and examination-ready reporting procedures.

03

Service provider oversight program development including vendor risk assessment frameworks, contract language templates, and ongoing monitoring procedures. We help you meet GLBA requirements for third-party service provider oversight with documented vendor management processes.

04

Incident response plan development with financial institution-specific notification procedures. We establish incident response plans that address GLBA notification requirements, state data breach laws, and regulatory reporting requirements specific to financial institutions.

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FAQ

Frequently Asked Questions

What is the difference between GLBA and PCI DSS?
GLBA is a federal law that applies to financial institutions and requires safeguarding customer financial information. PCI DSS is a contractual standard for organizations handling payment card data. GLBA has broader scope covering all customer information beyond payment data. Financial institutions need compliance with both.
Does GLBA apply to my business if we do not issue loans or take deposits?
Yes. GLBA applies to any business significantly engaged in financial activities, which the FTC interprets broadly. This includes mortgage brokers, auto dealers (that arrange financing), tax preparation services, real estate appraisers, check cashers, credit counselors, collection agencies, and other non-bank financial entities.
How often do we need to test our information security program?
The FTC Safeguards Rule requires penetration testing at least annually and vulnerability scanning at least quarterly. Risk assessments should be conducted periodically and whenever there are material changes in operations, business arrangements, or the threat landscape. Board reporting is required at least annually.
What happens during an FFIEC cybersecurity examination?
FFIEC examinations assess your cybersecurity program across categories including risk management, access controls, data protection, incident response, and vendor management. Examiners review policies and procedures, interview staff, test controls, and issue a report rating your cybersecurity maturity. Examinations typically last 2-5 days depending on institution size and complexity.

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Related Frameworks

Explore other compliance frameworks we support.

HITRUST CSF

Health Information Trust Alliance Common Security Framework - The Most Comprehensive Healthcare Security Certification...

HIPAA

Health Insurance Portability and Accountability Act - Protecting Patient Data Privacy and Security...

NIST CSF & NIST 800-171

National Institute of Standards and Technology Frameworks - The Cybersecurity Standards that Underpin U.S. Government an...

CMMC

Cybersecurity Maturity Model Certification - The DoD Mandatory Cybersecurity Standard for Defense Contractors...

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