FTC Safeguard Rules I 2025

Cyberattacks are on the rise, putting the financial sector—especially mortgage companies—squarely in the crosshairs. This surge in threats has intensified fraud risks and prompted regulators, including the FTC, to step up consumer protection measures.

Understanding the FTC Safeguards Rule

Originally introduced in 2003 under the Gramm-Leach-Bliley Act (GLBA) of 1999, the Safeguards Rule requires financial institutions to establish, implement, and maintain a comprehensive information security plan (ISP). In December 2021, the FTC updated this rule, broadening the definition of “financial institution” to include mortgage lenders and adding new requirements to strengthen cybersecurity across the industry.

Key Compliance Requirements

Under Section 314.4(c) of the updated FTC Safeguards Rule, mortgage lenders must meet nine core obligations:

1. Designate a Qualified Individual
   Appoint someone with the appropriate expertise—whether internal or external—to oversee your security program.

2. Conduct a Risk Assessment
   Document all locations where customer data is stored, identify potential threats, and update this assessment periodically to stay ahead of new risks.

3. Develop and Implement Security Safeguards

   • Access Controls: Limit and monitor access to sensitive data.
   • Encryption: Secure all data at rest and in transit.
   • Penetration Testing: Regularly test applications that handle customer information.
   • Multifactor Authentication: Add extra layers of security for system access.
   • Data Disposal: Safely dispose of customer information when it’s no longer needed.
   • Change Management: Integrate control processes based on risk assessments.
   • Monitoring and Logging: Track user activity and watch for unauthorized access.
   • Ongoing Validation: Conduct penetration tests and vulnerability assessments regularly.

4. Train Your Team
   Provide continual security awareness training for all staff, including specialized instruction for IT and security personnel.

5. Assess Third-Party Security
   Periodically evaluate the security practices of vendors and service providers who handle sensitive data on your behalf.

6. Keep Your ISP Current
   Update your Information Security Plan as new threats emerge and as your organization evolves.

7. Create a Written Incident Response Plan
   Have a clear, documented procedure for responding quickly and effectively to security breaches.

8. Annual Reporting
   Your designated security leader must report compliance status to senior management or the board at least once a year.

Meeting the New Standards

Because mortgage lenders handle highly sensitive data—bank statements, identity documents, tax records, and Social Security numbers—the updated Safeguards Rule emphasizes the importance of robust cybersecurity practices. Compliance isn’t just a regulatory box to check; it’s essential for maintaining customer trust and safeguarding your business against fraud and breaches.

How Antigen Security Can Help

At Antigen Security, we specialize in guiding mortgage lenders through the complex landscape of FTC compliance. Our comprehensive services include:

• Risk Assessments to identify vulnerabilities and protect critical data specific to FTC Safeguard.
• Customized Security Plans aligned with the latest regulatory and compliance standards.
• Employee Training & Awareness programs to reinforce a security-first culture.
• 24/7 Incident Response & Reporting frameworks that ensure swift, effective action in a breach.

Stay ahead of evolving threats and regulatory mandates. Let Antigen Security help you safeguard your clients’ data and reinforce your organization’s reputation for security and trust.