30 days. Then the FTC.
The May 2024 GLBA amendment added a 30-day FTC notification window for incidents touching 500+ consumers. The clock starts at “aware”, interpreted strictly. RiskWatch runs the breach playbook on the clock with the FTC notification template pre-staged so the deadline isn’t the thing you’re fighting.
- 30-day FTC breach clock with notification artifacts pre-staged
- Written Information Security Program (WISP) authoring
- Qualified Individual designation + encryption · MFA · pen testing · vendor oversight
- For legal counsel: chain-of-evidence trail + FTC reporting template
What is GLBA Safeguards Rule compliance software?
The 30-day FTC notification clock starts at “aware”, interpreted strictly. RiskWatch runs the breach playbook on the clock with the FTC Safeguards Rule notification template pre-staged, authors and maintains the Written Information Security Program, and tracks Qualified Individual reporting + encryption + MFA + penetration testing + service-provider oversight on a single audit trail. Penalties for missing the clock reach $100K per violation, the playbook is the cheapest insurance you can buy.
Pre-2023 you had no infosec program. The 2024 amendments changed everything.
Non-traditional FIs were disproportionately affected by the 2023/2024 Safeguards Rule updates. Before then, no requirement to maintain a formal infosec program existed. Now: WISP, designated Qualified Individual, technical safeguards, and 30-day FTC breach reporting, with personal liability for officers.
Pre-2023 you had no infosec program. The 2024 amendments changed everything.
Non-traditional FIs (auto dealers, tax preparers, mortgage brokers) had no Safeguards Rule program before 2023. The amendments made written program, Qualified Individual designation, technical safeguards, and breach reporting mandatory. WISP authoring + Qualified Individual workflow + technical-control library, built for the FI that's starting from zero.
30-day FTC breach notification clock. Counting starts when you “become aware.”
May 13, 2024 amendment requires FTC notification within 30 days for events affecting 500+ consumers. The clock starts at “awareness”, strictly interpreted by FTC. Breach playbook with timestamped triage, four-factor materiality assessment, FTC notification template, and the audit trail proving when awareness began.
Designated Qualified Individual. Officer liability. $10K + jail time.
The Qualified Individual designation creates personal accountability, and reporting requirements to the board annually. Officers face $10K per violation and up to 5 years of imprisonment for willful violations. Qualified Individual workflow with quarterly board reports, annual program review, and the documentation officers need to defend their compliance posture.
Every module a Safeguards Rule program needs, in one platform.
Built around the 9 WISP elements + Qualified Individual workflow + breach playbook. For the non-bank FI building a Safeguards program from scratch.
WISP + breach posture
9 WISP elements coverage, Qualified Individual reporting cadence, breach-clock readiness, service provider review status.
All 9 elements covered
Written Information Security Program per §314.4: risk assessment, access controls, encryption, MFA, monitoring, incident response, training, service provider oversight, periodic review.
Designation + reporting
Qualified Individual workflow with quarterly board reports, annual program review, and audit trail per §314.4(a).
30-day FTC clock
Breach assessment + four-factor analysis + FTC notification template per §314.5 (May 2024 amendment).
At rest + in transit
Customer info encryption coverage. FIPS-validated cryptography where required. Per-system tracking.
§314.4(f)
Due diligence, contract requirements, ongoing monitoring of service providers handling customer info.
§314.4(d)
Continuous monitoring of safeguards effectiveness. Quarterly reviews. Pen testing annually.
GLBA + NIST CSF + ISO 27001
WISP elements mapped to NIST CSF subcategories, ISO 27001 Annex A controls, NIST 800-53 r5 controls.
§314.4(b)
Documented risk assessment of customer info, internal + external risks. Annual update mandatory.
What you actually hold
Inventory of customer info, type, location, retention, disposal procedures per §314.4(c)(6).
Board + regulator
Annual board reports per Qualified Individual workflow. Examiner-ready documentation.
Examiner-grade
Timestamped log per WISP element, breach event, service provider review. Personal-liability defense.
From risk assessment to periodic review.
The 2023 amendments require a Written Information Security Program with 9 specific elements per §314.4. RiskWatch ships with all 9, risk assessment, access controls, encryption, MFA, monitoring, incident response, training, service provider oversight, and periodic review, pre-built and tailored to your scope.
- §314.4(a) Qualified Individual, designation + qualifications + reporting
- §314.4(b) Risk Assessment, documented + annually updated
- §314.4(c) Safeguards, access controls, encryption, MFA, secure development, change management, log monitoring, system inventory
- §314.4(d) Continuous Monitoring, + pen testing annually + vulnerability scanning every 6 months
- §314.4(e) Workforce Training, and security awareness
- §314.4(f) Service Provider Oversight, due diligence + contracts + ongoing monitoring
- §314.5 Breach Notification, 30-day FTC clock for 500+ events (May 2024)
GLBA + NIST CSF + ISO 27001 + SOC 2.
The Safeguards Rule controls overlap heavily with NIST CSF, ISO 27001, and SOC 2. RiskWatch maps every WISP element and technical safeguard to its counterpart, score once, satisfy multiple. Particularly relevant for FIs running SOC 2 alongside GLBA.
- NIST CSF 2.0, WISP elements map to Govern/Identify/Protect/Detect/Respond
- ISO 27001:2022 Annex A, encryption (A.8.24), MFA (A.5.16/A.5.17), monitoring (A.8.16)
- SOC 2 trust services, for FI SaaS providers running both
- FFIEC, for banks subject to both
- SEC Reg S-P, amendments effective Dec 2025 / June 2026 add 30-day customer breach notification
Who the FTC Safeguards Rule applies to.
Buy-here-pay-here, dealer financing, vehicle title loans
Originators, servicers, residential and commercial
CPAs, EAs, individual preparers handling tax data
Institutions handling student financial aid
From WISP draft to FTC-defensible in five stages.
Non-bank FIs starting from no prior infosec program complete WISP authoring in 4-6 weeks. Continuous compliance follows.
Designate Qualified Individual
Designation per §314.4(a). Reporting workflow setup. Quarterly board cadence established.
Author WISP
All 9 WISP elements per §314.4. Risk assessment documented. Customer info inventory built.
Implement technical safeguards
Encryption + MFA + access control + monitoring per §314.4(c). Pen testing scheduled.
Monitor + report + reassess
Continuous monitoring per §314.4(d). Quarterly board reports. Annual WISP review. Breach-readiness drills.
FTC-defensible posture
WISP + Qualified Individual + technical safeguards + breach playbook all current. Officer-defense documentation in audit trail.
The Safeguards Rule program that finally got Qualified Individual buy-in.
Real non-bank FIs. Real WISP programs. Real Qualified Individual designations defended.
Pre-2023, we had no formal infosec program. Six months later we have a defensible WISP that the auditor signed off on.
“30-day FTC breach clock used to terrify us. Playbook with template + audit trail + four-factor analysis means we're ready, not panicked.”
“Qualified Individual board reports auto-generated quarterly. The board sees real metrics, not narrative. Made my job 10x easier.”
Plus every framework that overlaps GLBA, cross-mapped.
WISP elements map to NIST CSF, ISO 27001, SOC 2, FFIEC. Most FIs run 2-3 frameworks simultaneously.
Take RiskWatch home before you sign anything.
Three downloads. Build the WISP from zero or refine an existing program.
GLBA WISP Template (9 elements)
Thirty-page Written Information Security Program template covering all 9 §314.4 elements with examples for non-bank FIs.
- All 9 §314.4 elements
- Tailored for non-bank FIs
- Risk assessment + breach playbook
GLBA Breach Notification Playbook
FTC-aligned breach playbook covering the 30-day clock per §314.5, four-factor materiality analysis, and FTC notification template.
- 30-day FTC clock playbook
- Four-factor analysis
- FTC notification template
GLBA Platform Buyer's Guide
Vendor scorecard, WISP-authoring depth, breach-playbook features, Qualified Individual workflow, pricing.
- Feature matrix · 6 vendors
- Scorecard template
- Pricing benchmarks
Common questions, answered up front.
About GLBA Safeguards Rule, the 2023/2024 amendments, WISP requirements, the breach clock, and how RiskWatch covers all of them.
What is GLBA Safeguards Rule compliance software?
Who is subject to the FTC Safeguards Rule?
What changed in the 2023 amendments?
How does the 30-day FTC breach clock work?
Is there a free trial?
WISP authoring + Qualified Individual designation this week.
Start a 30-day free trial, all 9 WISP elements, Qualified Individual workflow, breach playbook, technical safeguards library, service provider oversight. No credit card required.
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