FTC Safeguards Rule Compliance
The FTC's amended Safeguards Rule (16 CFR Part 314) is now the operative cybersecurity baseline for tens of thousands of CPA firms, registered investment advisors, mortgage brokers, financial advisors, and other "financial institutions" under the Gramm-Leach-Bliley Act's broad definition.
What this covers
LayerLogix delivers end-to-end Safeguards Rule compliance: Designated Qualified Individual services through our vCISO program, firm-specific WISPs, risk assessments, encryption, MFA, Privileged Access Management (PAM), continuous monitoring, vendor management, incident response planning, and annual board reporting.
FTC Safeguards Rule · From scope to a working program
How the Safeguards Rule lands in a small office
Tax preparers, mortgage brokers, advisors and dealers that extend credit can all fall under it. Here's how its required pieces become real controls and real evidence. Tap a lens to dive in, or let it play.
Before · Who the rule reaches
Not a bank? The FTC may still treat you as one.
The Safeguards Rule borrows the Gramm-Leach-Bliley Act's broad idea of a financial institution. Tax preparers, CPA firms, mortgage brokers, advisors, check cashers and car dealers that extend credit can all land in it. If you keep consumers' private financial details, plan as if you're covered.
What LayerLogix does
- Confirm whether your firm counts as a financial institution
- Identify which systems hold in-scope customer information
- Point out where a written opinion from counsel helps
Step 1 · A Designated Qualified Individual
One named person owns the whole program
The amended rule wants one person accountable: the Designated Qualified Individual. They don't have to be on payroll or hold a particular certification, but they need the responsibility, the authority and the know-how. Hand the title to someone without the know-how and the risk just lands on them.
What LayerLogix does
- Serve as your DQI through our vCISO service
- Or train and back up someone on your own team
- Handle the documentation and board reporting the role needs
Step 2 · The written risk assessment
Follow one customer file from intake to shredder
A risk assessment isn't a questionnaire. It traces how customer information comes in, moves, sits and leaves, across the cloud, the office server, phones and vendors, and writes down every gap it finds. Pick a file and watch the gaps show up. Then it gets redone every year, because offices change.
What LayerLogix does
- Trace customer data across cloud, office, mobile and vendors
- Rate each gap by risk and effort, in writing
- Keep the assessment current with a yearly reassessment
Findings · Tax return
Step 3 · From written plan to working controls
Each part of the WISP becomes a control you can point to
A template WISP can say all the right things while nothing in the office enforces them. We write your plan from your own risk assessment, then turn each section into a working control: encryption, MFA, application allowlisting, change approvals, disposal. Each one leaves its own evidence behind.
What LayerLogix does
- Write a WISP for your firm, not a filled-in template
- Deploy encryption, MFA and Privileged Access Management
- Set up the logs and records each control should leave behind
Step 4 · Monitoring or scheduled testing
Watch it all year, or test it on a schedule
The rule gives you two routes: continuous monitoring of your systems, or a penetration test every year plus vulnerability assessments twice a year. We can run either one, and the reports come written so your DQI can use them in the annual report. Switch routes to compare what each leaves behind.
What LayerLogix does
- Run continuous monitoring across your systems
- Schedule the yearly pen test and the twice-yearly scans
- Format the results for your DQI's annual report
Step 5 · Incident response and the FTC notice
A breach starts a clock. The plan already knows it.
When a notification event involves 500 or more consumers, the FTC has to hear about it as soon as possible, and no later than 30 days after you discover it. A written incident response plan means the first days go to containing and counting, not to arguing over who calls whom.
What LayerLogix does
- Build an incident response plan with the required notices
- Train everyone on your team to report problems quickly
- Help you document the event and prepare the FTC notice
After · The program runs on a calendar
Once a year, your DQI shows the board the whole picture
Your DQI reports to the board, or to a senior officer if there's no board, every year. When evidence has been collected all along, that report comes together from records: the risk reassessment, control tests, incident log, vendor reviews and training. The year doesn't get rebuilt from memory.
What LayerLogix does
- Collect the evidence as the year goes, not the week before
- Reassess your vendors and their safeguards every year
- Prepare the annual report your DQI presents
Showing Before · Who the rule reaches: Not a bank? The FTC may still treat you as one.
What We Offer
Comprehensive solutions tailored for Houston-area businesses
Designated Qualified Individual (DQI)
The amended Safeguards Rule requires a single Designated Qualified Individual responsible for your information security program. We can serve as your DQI through our vCISO service, or train and support an internal candidate — including all of the documentation, board reporting, and continuous oversight the rule expects.
Written Information Security Plan (WISP)
We author your firm-specific WISP from scratch, mapped directly to the nine elements 16 CFR § 314.4 requires: risk assessment, access controls, encryption, MFA, secure disposal, change management, monitoring, incident response, and service-provider oversight. Auditor-ready, not boilerplate.
Risk Assessment & Annual Reassessment
Documented risk assessment covering all customer information your firm collects, transmits, stores, and disposes of — across cloud, on-premise, mobile, and third-party systems. Annual reassessment is mandatory under the rule, and we keep yours current.
Encryption, MFA & Privileged Access Management
We deploy the technical controls the rule requires: encryption of customer data at rest and in transit, multi-factor authentication for all individuals accessing customer data, and Privileged Access Management (PAM) — application allowlisting that satisfies access control and change management requirements in a single deployment.
Continuous Monitoring & Penetration Testing
Continuous monitoring of your information system or — if you cannot do continuous monitoring — annual penetration testing and biannual vulnerability assessments. We deliver both, with reports formatted to support your DQI's annual board attestation.
Service Provider Due Diligence
The rule requires you to oversee the service providers who handle customer information. We deliver a vendor inventory, contractual safeguards review, and annual reassessment program — including any third-party assessment evidence (SOC 2, ISO 27001) you need to retain.
Why Choose LayerLogix?
Serving businesses throughout the Greater Houston area including Houston, The Woodlands, Spring, Sugar Land, Katy, Pearland, Conroe, Dallas, Fort Worth, Austin.
Avoid FTC Enforcement & Civil Penalties
The FTC can assess civil penalties of more than $50,000 per violation per day under the Safeguards Rule. CPA firms, RIAs, mortgage brokers, and many other "financial institutions" under the rule's broad definition are now in scope — and enforcement is active. We get you compliant before an examiner asks.
Defensible Documentation
Your DQI must annually report to the board. We produce the documentation that makes that report defensible: risk assessment outputs, control test evidence, incident logs, vendor reviews, and training records. Audit-ready, not after-the-fact reconstructions.
Cyber Insurance Premium Reduction
Carriers now require Safeguards Rule compliance attestations on every renewal application for financial firms. Documented compliance — particularly PAM, MFA, and encryption — frequently reduces premium quotes by 10-25% on renewal.
Win and Retain Enterprise Clients
Larger clients and broker-dealer relationships increasingly require evidence of formal information security programs. A Safeguards Rule-compliant WISP is the same artifact those clients are asking for.
A Path to SOC 2 and Beyond
The Safeguards Rule controls overlap heavily with SOC 2 Common Criteria, NIST CSF, and HIPAA Security Rule. We build your Safeguards Rule program in a way that ladders directly into these other frameworks if you need them later.
Our Process
Frequently Asked Questions
Is my CPA firm actually subject to the FTC Safeguards Rule?▼
What changed in the 2021/2023 Safeguards Rule amendments?▼
Who can serve as our Designated Qualified Individual?▼
How does Privileged Access Management (PAM) help with Safeguards Rule compliance?▼
Do we have to notify the FTC if we have a breach?▼
How much does Safeguards Rule compliance cost?▼
Do you provide FTC Safeguards Rule Compliance in Houston and nearby areas?▼
What does FTC Safeguards Rule Compliance cost for a Houston business?▼
Ready to Get Started?
Contact LayerLogix today for a free consultation. We serve businesses throughout Houston, The Woodlands, Spring, and the surrounding Greater Houston area.