GLBA Compliance Services for Non-Bank Financial Institutions and Advisers
GLBA compliance confuses people because the law has no single rulebook. The Gramm-Leach-Bliley Act sets the duties; the agency that regulates you writes the rule. For most small firms that means the FTC Safeguards Rule; for investment advisers it means the SEC's Regulation S-P; for New York insurance licensees it means DFS. NetSys sorts out which applies, then builds one program that satisfies it and the state laws that overlap.
The short answer
The Gramm-Leach-Bliley Act requires financial institutions to protect the security and confidentiality of customers' nonpublic personal information and to tell customers how that information is shared. It does this through two sets of rules. The Safeguards Rule requires a written information security program with administrative, technical and physical safeguards. The Privacy Rule requires privacy notices and, in some cases, an opt-out from sharing with nonaffiliated third parties. Each regulator implements those duties for the institutions it oversees: the FTC for non-bank firms, the SEC for advisers and broker-dealers, the banking agencies for banks. NetSys delivers GLBA compliance for small and mid-sized financial firms by implementing the safeguards, supporting the privacy mechanics, overseeing vendors and keeping evidence. We are not a law firm and do not certify compliance.
A mortgage broker in New Jersey, a tax practice in Nassau County and a wealth adviser in Fairfield County all hold the same kind of data: names tied to account numbers, Social Security numbers and income. GLBA treats all three as financial institutions. What differs is who checks: the FTC, the SEC or, for a New York insurance agency, DFS. The controls they expect overlap almost entirely.
Our GLBA compliance work starts by identifying your regulator and the rule that implements the act for you, then building to the strictest reading among the rules that apply. A firm that meets the FTC Safeguards Rule's element list also satisfies the NY SHIELD Act's safeguard requirement by the statute's own terms, and most of what a cyber insurer asks.
One Program, Mapped to the Rule That Applies to You
We begin with a free assessment or our free Tier 1 external penetration test. Then we confirm your regulator, inventory the nonpublic personal information you hold and the systems and vendors that touch it, and write the risk assessment. The technical safeguards go in through Microsoft 365, Entra ID and Intune: MFA, encryption, access control, logging, monitoring and backups. We support the qualified individual or CISO the applicable rule requires, review service provider contracts, and work with your counsel on privacy notice delivery and opt-out tracking. Evidence is organized against the rule's own element list so an examiner can be answered from records.
What Our GLBA Compliance Services Cover
Regulator Mapping and Program Design
Which rule implements GLBA for you, and what it demands.
- Determination of the applicable rule: FTC Safeguards, SEC Reg S-P, DFS or a banking agency's guidelines
- Written information security program and risk assessment built to that rule's structure
- Qualified individual or CISO designated, with vCISO support available
- Crosswalk to NY SHIELD Act, cyber insurance and customer questionnaires
Safeguards Rule Controls
The technical program under the written one.
- MFA and conditional access for every user reaching nonpublic personal information
- Encryption on devices, in email and in cloud storage where customer data sits
- Endpoint detection and response with monitoring, logging and vulnerability management
- Secure disposal and retention rules for customer records, paper and electronic
Privacy Rule Mechanics and Vendors
Notices, opt-outs and the third parties you share with.
- Systems support for delivering privacy notices and recording opt-outs, with counsel owning the content
- Inventory of nonaffiliated third parties and service providers that receive customer information
- Vendor due diligence and contract terms that require safeguards and breach notice
- Data flow documentation showing where customer information goes and why
Testing, Response and Evidence
Prove the program works and keep the proof.
- Penetration testing and vulnerability assessments on the applicable rule's schedule
- Incident response plan with notification duties for your regulator and affected customers
- Training records, access reviews and an annual report to ownership assembled from evidence
- Delivered remotely nationwide; on-site in our published coverage areas
Why Financial Firms Choose NetSys for GLBA Compliance
Let The Netsys Group assess and help you resolve your exposure. Call 845-203-3914 for your complimentary risk assessment consultation today!
- We identify the rule that applies before building anything, so the program fits your examiner
- MFA, encryption, monitoring and disaster recovery are included in the managed agreement
- The same evidence answers GLBA, the NY SHIELD Act and cyber insurance questions
- Clear boundaries: we run the controls; counsel owns notices and legal determinations
- Month to month, starting with a free assessment or free external penetration test
Where we deliver GLBA Compliance Services
GLBA Compliance Services in New York City · GLBA Compliance Services in New Jersey · GLBA Compliance Services in Stamford, CT — and remotely wherever your systems run. See all locations and service areas.
GLBA Compliance Services FAQs
What is GLBA compliance?
GLBA compliance means meeting the Gramm-Leach-Bliley Act's two core duties: protecting customers' nonpublic personal information with a written security program (the Safeguards Rule) and telling customers how their information is shared, with opt-out rights where required (the Privacy Rule). The specific requirements come from your regulator's rule under the act; for most small non-bank firms that is the FTC Safeguards Rule.
Who has to comply with GLBA?
Any company significantly engaged in financial activities: banks and credit unions, mortgage lenders and brokers, auto dealers that finance or lease, consumer lenders, tax preparers and accounting firms, investment advisers and broker-dealers, insurance companies and agencies, and collection agencies. The label is broader than most owners assume, and being small does not exempt you.
What is the difference between GLBA and the FTC Safeguards Rule?
GLBA is the statute; the FTC Safeguards Rule is the regulation the Federal Trade Commission wrote to implement GLBA's security requirement for the financial institutions it oversees. If you are a dealer, tax preparer, mortgage broker or non-bank lender, the Safeguards Rule is your GLBA security obligation. Advisers get the same duty from the SEC's Regulation S-P, and banks from their prudential regulators' guidelines.
How much does GLBA compliance cost?
It depends on how many systems hold nonpublic personal information and how much of the safeguard set already exists. For NetSys managed clients the technical safeguards are part of the monthly agreement, so the added cost is the written program, vendor oversight and qualified individual support. We do not publish prices; the free assessment sizes the gap.
Do we need GLBA compliance if we already comply with NYDFS Part 500?
Yes, but the overlap is nearly complete. A New York insurance agency is regulated by DFS, which enforces both GLBA's privacy provisions for insurers and its own Part 500 cybersecurity regulation. A Part 500 program covers the safeguard side. The privacy notice duties remain separate. We map your Part 500 controls to the GLBA elements so the overlap is documented.
Does GLBA require a privacy notice?
Generally yes. Financial institutions must give customers a clear notice of their privacy practices when the relationship begins and, in most cases, annually, with an opt-out where information is shared with nonaffiliated third parties. The notice content is a legal matter for counsel. NetSys handles the mechanics: delivery through your systems, records of who received it, and tracking of opt-outs.
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