The FTC’s recently updated rule implementing GLB standards for safeguarding customer information replaces the flexibility previously given to financial institutions in developing an information security program with new prescriptive requirements.  Our discussion topics include what these new requirements mean for specific aspects of such programs, assigning employee responsibility, conducting risk assessments, installing access controls, using

The FTC has proposed amendments to its 2003 Safeguards Rule and 2000 Privacy Rule, applicable to financial institutions under the Gramm Leach Bliley Act (GLBA).  The proposed changes are informed by the FTC’s enforcement experience and are intended to keep pace with technological developments.

The Safeguards Rule requires financial institutions to have a comprehensive information