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
GLBA compliance means meeting the Gramm-Leach-Bliley Act's two duties for financial institutions: protect customers' nonpublic personal information with a written security program (the safeguards side), and tell customers how that information is shared, with an opt-out where the rules require one (the privacy side). The detailed requirements come from the regulator that oversees you: the FTC Safeguards Rule for most non-bank firms such as dealers, tax preparers and lenders, the SEC's Regulation S-P for advisers and broker-dealers, and the banking agencies' guidelines for banks. NetSys builds and runs the safeguards, supports the privacy mechanics, oversees vendors and keeps the 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 our free remote external penetration test, limited to available information and agreed external scope. Under a separate assessment and implementation scope, 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
Fifteen minutes with a NetSys engineer, not a salesperson, and you will know where your glba compliance services stands and what it would take to fix it. Call 845-203-3914 or request a call to discuss the scope and next steps.
Who does the work: meet the NetSys team on our About page.
- 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 remote external penetration test within an agreed external scope
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. We also support clients remotely wherever their 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. Which rule applies matters too: a firm under the FTC Safeguards Rule that holds information on fewer than 5,000 consumers is exempt from four of its provisions, while an adviser under Regulation S-P has its own incident response and notice duties. 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; we agree the broader review and implementation scope before quoting.
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.
What is included in GLBA compliance services?
First, a written determination of which rule implements GLBA for you. Then a written information security program and risk assessment built to that rule's structure; the technical safeguards (MFA, encryption, access control, logging, monitoring and backups); a vendor inventory with contract terms reviewed; systems support for privacy notice delivery and opt-out records; testing on the rule's schedule; an incident response plan; and an annual report to ownership assembled from evidence. Counsel owns the notice wording and every legal determination.
How does a GLBA engagement start?
By confirming your regulator, because that decides the rule, its required elements and who must be told after a breach. Then we inventory the nonpublic personal information you hold, the systems and vendors that touch it and any paper records, and write the risk assessment from that inventory. Our free remote external penetration test, within an agreed external scope, can run alongside as a first look at what the business exposes to the internet.
Who handles support and escalations?
NetSys engineers run and monitor the safeguards under the managed agreement. The help desk is staffed seven days a week from 4 a.m. to 11 p.m. Eastern time, and emergency service is available 24/7. A suspected security event follows the incident response plan, which names your qualified individual or CISO and your counsel as the people who decide on notices, such as the FTC's 30-day notice for events affecting 500 or more consumers. We contain the event and supply the facts from the logs.
Guides on this topic
- FTC Safeguards Rule Compliance
- SEC Cybersecurity Rules for RIAs
- NYDFS 23 NYCRR 500 Compliance
- IT for Accounting Firms
- IT for Auto Dealers
- IT for Financial Services Firms
- Free External Penetration Test
- Cybersecurity for financial services firms under NYDFS, SEC and FTC rules
- New York SHIELD Act compliance services
- vCISO support for the qualified individual or CISO role
- Incident response plans with regulator and customer notice steps
One program built to the rule your examiner uses.
GLBA sets the duty. Your regulator writes the rule, and we settle that first, since a dealership answers to the FTC Safeguards Rule and an adviser to Regulation S-P. The safeguards go in once, and the same evidence answers the NY SHIELD Act. Counsel owns the notice wording; we handle delivery and opt-out records.