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: FTC Safeguards Rule business guidance
What documents does the Safeguards Rule actually require for a mortgage lender?
Details
Policywright splits the operating record into a WISP, incident response plan, acceptable use policy, and access control policy. For a mortgage lender, those documents should map to Borrower files include credit, income, tax transcript, bank, employment, appraisal, title, underwriting, and closing data. Information usually crosses a loan-origination system, warehouse or investor portal, settlement vendors, and servicing handoff records.
Primary source: FTC Safeguards Rule business guidance.
FAQ
What documents does the Safeguards Rule actually require for a mortgage lender?
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 lender?
Borrower files include credit, income, tax transcript, bank, employment, appraisal, title, underwriting, and closing data. Information usually crosses a loan-origination system, warehouse or investor portal, settlement vendors, and servicing handoff records.
Is this legal advice?
No. It is source-cited educational content for a template product, not legal advice.