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)(xiii)
What documents does the Safeguards Rule actually require for a finder?
Details
Policywright splits the operating record into a WISP, incident response plan, acceptable use policy, and access control policy. For a finder, those documents should map to Finder data may live in lead forms, marketplace profiles, referral databases, eligibility screens, CRM records, email introductions, and analytics exports. The WISP should distinguish ordinary marketing leads from consumer financial information collected to make a financial-service match.
Primary source: 16 CFR 314.2(h)(2)(xiii).
FAQ
What documents does the Safeguards Rule actually require for a finder?
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 finder?
Finder data may live in lead forms, marketplace profiles, referral databases, eligibility screens, CRM records, email introductions, and analytics exports. The WISP should distinguish ordinary marketing leads from consumer financial information collected to make a financial-service match.
Is this legal advice?
No. It is source-cited educational content for a template product, not legal advice.