GLBA Sections 6804 and 6805 - rulemaking + enforcement. SECTION 6804 RULEMAKING (post Dodd-Frank): CFPB (Bureau of Consumer Financial Protection) + SEC (Securities and Exchange Commission) + CFTC (Commodity Futures Trading Commission) have authority to prescribe regulations as may be necessary to carry out the purposes of this subchapter with respect to financial institutions + other persons subject to their respective jurisdictions; CFPB does NOT have authority to prescribe regulations with respect to the safeguarding standards under Section 6801. SECTION 6805 ENFORCEMENT: this subchapter and the regulations prescribed thereunder shall be enforced by - (1) APPROPRIATE FEDERAL BANKING AGENCY under 12 USC 1818 for national banks (OCC) + state member banks (Federal Reserve) + state non-member banks (FDIC) + federal credit unions (NCUA) + savings associations (FDIC/OCC); (2) NCUA for federal credit unions; (3) FTC for financial institutions not described in (1)/(2) including non-bank consumer finance + check-cashers + money-services + tax preparers + automobile dealers + collection agencies + non-bank lenders + automobile + retail finance + mortgage brokers + originators (since CFPB establishment); (4) SEC for broker-dealers + investment companies + investment advisers; (5) CFTC for futures commission merchants + commodity trading advisors + commodity pool operators + introducing brokers; (6) STATE INSURANCE AUTHORITIES for insurance providers; (7) CFPB for non-bank financial institutions over which CFPB has authority under Dodd-Frank Title X. State insurance preemption + State law remains in effect unless inconsistent with this subchapter (Sec. 6807). 2024-2025 STATUS: FTC retains primary GLBA enforcement for non-bank entities; CFPB enforces GLBA in respect of Dodd-Frank Section 1033 + larger participants; SEC enforces Reg S-P. ENFORCEMENT ACTIONS: TaxSlayer 2017 + Mortgage Solutions FCS 2020 + Drizly 2022 + RingCentral + Equifax + Wyndham + Wyze + others.
The graph holds this control, the 0 it maps to, and the evidence behind each claim, over MCP and REST.