The FTC Safeguards Rule requires financial institutions to implement a comprehensive information security program — or face significant fines and enforcement action. We build it, document it, and keep it current.
Does This Apply To You?
The FTC Safeguards Rule applies to any business that is "significantly engaged" in financial activities — not just banks.
Registered Investment Advisors, wealth managers, and financial planners handling client financial data.
Accounting firms and tax preparers who collect, process, or store client financial records and tax information.
Mortgage brokers and non-bank lenders who collect, process, or store nonpublic personal financial information in the course of originating or servicing loans.
Independent insurance agents and agencies that collect nonpublic personal information from policyholders.
Check cashers, payday lenders, credit counselors, and money transfer services subject to FTC jurisdiction.
Franchised and independent car dealers that arrange or facilitate financing for customers are explicitly covered under the Safeguards Rule — including Buy Here Pay Here operations.
If your business touches nonpublic personal financial information in any capacity, you may be covered. We'll tell you for certain — at no charge.
The Consequences of Non-Compliance
FTC civil penalties up to $50,120 per violation per day
Mandatory breach notification to customers and the FTC within 30 days of a security event affecting 500+ customers
FTC enforcement investigations, consent decrees, and mandatory audits
Reputational damage and client loss following a publicized breach or FTC action
Personal liability exposure for the Qualified Individual (QI) named in your program
What Compliance Looks Like
A written, board-approved Information Security Program
A designated Qualified Individual (QI) — we can serve in this role
Documented risk assessments, controls, and annual reporting
A tested incident response plan with 30-day breach notification readiness
Continuous monitoring and annual program reviews to stay current
The Rule Broken Down
The amended Safeguards Rule specifies exactly what your program must include. We map our services directly to each requirement.
Qualified Individual
Designate a QI to oversee, implement, and enforce your information security program.
We serve as your outsourced QI or support your internal designee with full program documentation.
Risk Assessment
Conduct a written risk assessment identifying foreseeable threats to customer information.
We perform a comprehensive written risk assessment covering all systems, vendors, and data flows.
Safeguards Implementation
Implement and regularly test technical, physical, and administrative safeguards.
We deploy, configure, and validate controls including encryption, MFA, EDR, firewalls, and access management.
Service Provider Oversight
Select and oversee service providers that maintain appropriate safeguards.
We conduct vendor due diligence reviews and maintain a service provider inventory with contract requirements.
Access Controls
Limit access to customer information to authorized users with a need to know.
We implement role-based access control (RBAC), privileged access management, and quarterly access reviews.
Encryption
Encrypt customer information in transit and at rest.
We ensure end-to-end encryption across all storage, email, and transmission channels.
Multi-Factor Authentication
Implement MFA for any individual accessing customer information.
We deploy and enforce MFA across all systems, cloud platforms, and remote access points.
Incident Response Plan
Establish a written incident response plan with defined roles, procedures, and notification requirements.
We build and test your IRP, including the 30-day FTC breach notification workflow.
Annual Reporting
The QI must report to the board (or senior officer) at least annually on the status of the program.
We prepare your annual compliance report, board presentation materials, and program status summary.
Our Deliverables
Everything we produce is documented, defensible, and audit-ready from day one.
A complete, board-ready WISP tailored to your business, data environment, and risk profile — not a generic template.
A documented risk assessment identifying threats, vulnerabilities, and the safeguards in place to address each — updated annually.
A complete service provider inventory with due diligence documentation and contractual security requirements tracked and maintained.
A tested IRP with clear roles, escalation paths, and a 30-day FTC breach notification workflow — exercised annually.
The QI-signed annual report for your board or senior officer, covering program status, risk assessment results, and exceptions.
We don't just document — we deploy. MFA, encryption, access controls, EDR, and continuous monitoring configured and maintained.
The Qualified Individual Requirement
The FTC Safeguards Rule requires you to designate a Qualified Individual to implement and supervise your information security program. This person must report to your board at least annually and be held accountable for the program's effectiveness.
Most small and mid-sized financial businesses don't have a full-time CISO on staff — and they shouldn't have to. We fill this role as your outsourced QI, bringing enterprise-grade expertise without the enterprise-level overhead.
Why Trust NKC With Your Compliance
36+
Years IT & Cybersecurity Experience
6
Active Professional Certifications
3
Advanced Degrees in IT & Business
∞
Accountability. No Offshore Help Desks.
Schedule a 30-minute meeting. We'll review your current security posture against the FTC Safeguards Rule requirements and give you an honest gap analysis — at no cost and no obligation.
Schedule a Meeting →All conversations are confidential. | (661) 812-3626