The rule requires a written information security program and, unless exempt, specific written risk-assessment, testing, incident-response, and reporting records. Citation: 16 CFR 314.4 and 314.6.
Primary source: 16 CFR 314.2(h)(2)(xii)
What documents does the Safeguards Rule actually require for a credit counselor or financial advisor?
Details
Policywright splits the operating record into a WISP, incident response plan, acceptable use policy, and access control policy. For a credit counselor or financial advisor, those documents should map to Information lives in intake questionnaires, budgets, creditor lists, account statements, planning software, CRM notes, document portals, payment-plan records, and advisor email. The WISP should separate advice records from any payment or debt-management data handled by vendors.
Primary source: 16 CFR 314.2(h)(2)(xii).
FAQ
What documents does the Safeguards Rule actually require for a credit counselor or financial advisor?
The rule requires a written information security program and, unless exempt, specific written risk-assessment, testing, incident-response, and reporting records. Citation: 16 CFR 314.4 and 314.6.
What is the data-flow issue for a credit counselor or financial advisor?
Information lives in intake questionnaires, budgets, creditor lists, account statements, planning software, CRM notes, document portals, payment-plan records, and advisor email. The WISP should separate advice records from any payment or debt-management data handled by vendors.
Is this legal advice?
No. It is source-cited educational content for a template product, not legal advice.