FTC GLBA Safeguards Rule (16 CFR Part 314)
FTC Safeguards Rule: Effective Date, Small Institution Exemption and 2024-2025 Pipeline (314.5, 314.6, Coordination)

FTC GLBA Safeguards Rule (16 CFR Part 314) FTC-Safeguards-2024-2025-Status: 2024-2025 Implementation Status, FTC Enforcement Actions and Anticipated Amendments

FTC Safeguards Rule 2024-2025 implementation status. EFFECTIVE DATES: full 2021 amendments effective 9 January 2022 + 13 January 2023 (delayed elements) + 13 May 2024 (FTC notification requirement). 2024-2025 FTC ENFORCEMENT ACTIONS (publicly published): multiple settlements + complaints against (a) MORTGAGE BROKERS for lack of WISP + Qualified Individual + MFA + encryption; (b) AUTO DEALERS for insufficient safeguards + service-provider oversight; (c) TAX PREPARERS for breach notification failures + cyber-incident response gaps; (d) CONSUMER REPORTING AGENCIES for systemic safeguards deficiencies; (e) INVESTMENT ADVISORS (where SEC + FTC dual-jurisdictional). PENALTIES range from civil penalties up to USD 50,000-100,000 per violation (FTC Act Section 5(m)) + injunctive relief + monetary refunds to affected consumers + COMPLIANCE MONITORING. ANTICIPATED 2025 AMENDMENTS (per FTC public agenda): (a) AI-RELATED RISK REQUIREMENTS - safeguards for AI systems processing customer information; (b) SUPPLY-CHAIN DUE DILIGENCE enhancements; (c) INTERAGENCY COORDINATION with CFPB + banking agencies + state regulators; (d) BREACH NOTIFICATION timeline + scope refinements; (e) SMALL INSTITUTION threshold + simplified compliance review. INDUSTRY GUIDANCE: FTC + ABA + IIA + ISACA publish guidance + benchmarking surveys + AI vendor evaluation checklists.

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