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 an account servicer?
Details
Policywright splits the operating record into a WISP, incident response plan, acceptable use policy, and access control policy. For an account servicer, those documents should map to Servicing data lives in boarding files, account platforms, payment systems, call-center tools, correspondence queues, dispute workflows, vendor portals, and investor or client reports. The WISP should identify data received from the owner and data generated by servicing activity.
Primary source: FTC Safeguards Rule business guidance.
FAQ
What documents does the Safeguards Rule actually require for an account servicer?
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 an account servicer?
Servicing data lives in boarding files, account platforms, payment systems, call-center tools, correspondence queues, dispute workflows, vendor portals, and investor or client reports. The WISP should identify data received from the owner and data generated by servicing activity.
Is this legal advice?
No. It is source-cited educational content for a template product, not legal advice.