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)(xi)
What documents does the Safeguards Rule actually require for a mortgage broker?
Details
Policywright splits the operating record into a WISP, incident response plan, acceptable use policy, and access control policy. For a mortgage broker, those documents should map to Borrower data moves through lead intake, loan-origination systems, credit pulls, document-upload portals, income and asset verification, lender submissions, and broker email. The WISP should name both the LOS and the lender/vendor portals where nonpublic personal information leaves the broker's direct system.
Primary source: 16 CFR 314.2(h)(2)(xi).
FAQ
What documents does the Safeguards Rule actually require for a mortgage broker?
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 mortgage broker?
Borrower data moves through lead intake, loan-origination systems, credit pulls, document-upload portals, income and asset verification, lender submissions, and broker email. The WISP should name both the LOS and the lender/vendor portals where nonpublic personal information leaves the broker's direct system.
Is this legal advice?
No. It is source-cited educational content for a template product, not legal advice.