Primary references
Use the original standards below to check terminology and requirements. These references explain the standards; they do not endorse CISGuard or independently verify its product coverage.
GLBA Compliance Automation
CISGuard automates the technical safeguards required by the Gramm-Leach-Bliley Act Safeguards Rule, with continuous evidence aligned to the December 2021 amendments and the broader FFIEC Cybersecurity Assessment Tool.
Overview
The Gramm-Leach-Bliley Act (GLBA) Safeguards Rule (16 CFR Part 314), enforced by the FTC for non-bank financial institutions and by federal banking regulators (OCC, FDIC, Federal Reserve, NCUA) for depository institutions, requires financial institutions to develop, implement, and maintain a comprehensive information security program with specific technical controls protecting consumer nonpublic personal information (NPI). The December 2021 amendments substantially strengthened the technical-controls expectations, requiring multi-factor authentication for any system containing NPI (Section 314.4(c)(6)), encryption for NPI at rest and in transit (Section 314.4(c)(3)), regular monitoring and testing (Section 314.4(d)), and Qualified Individual oversight (Section 314.4(a)). The FFIEC Cybersecurity Assessment Tool (CAT) operationalizes broader supervisory expectations for federally regulated depository institutions. CISGuard's continuous CIS benchmark scanning produces the evidence both the FTC Safeguards Rule and FFIEC CAT examiners walk through.
GLBA Safeguards Rule December 2021 amendments operationalize a control set substantially overlapping NIST 800-53 / NIST 800-171 / NYDFS, with the FFIEC Cybersecurity Assessment Tool providing the supervisory examination framework for depository institutions. CISGuard's continuous CIS benchmark scanning produces the evidence the FTC examiner (for non-bank) and federal banking regulator (for depository institutions) walk through during Safeguards Rule examination and the broader FFIEC CAT supervisory cycle. Section 314.4(c)(6) MFA evidence, Section 314.4(c)(3) encryption evidence, and Section 314.4(d) monitoring evidence all flow from the same CIS benchmark output.
Configuration evidence supports an assessment; it does not by itself establish certification, authorization or full compliance. Review coverage boundaries and evaluation evidence.
Control mapping
Each CIS control is tagged with its framework reference. One scan produces the per-framework coverage report, with satisfied, partially satisfied and not-met status for every control.
| Control area | Controls | Mapped by |
|---|---|---|
| Section 314.4(c)(1) Access Controls | Authentication, authorization, periodic review | CIS Account + Identity benchmarks |
| Section 314.4(c)(3) Encryption | NPI at rest and in transit | CIS Cryptography + TLS benchmarks |
| Section 314.4(c)(4) Secure Development | In-house developed applications | CIS configuration evidence on development infrastructure |
| Section 314.4(c)(6) MFA | MFA on any system containing NPI | CIS Identity + Authentication benchmark evidence |
| Section 314.4(d) Monitoring and Testing | Continuous monitoring + annual penetration testing | Continuous CIS scanning + drift detection |
| Section 314.4(h) Incident Response | Written incident response plan + practice | Drift detection + SIEM webhook + audit trail |
Auditor evidence
Auditor-grade outputs in PDF, HTML, JSON, CSV and SARIF. No spreadsheets, no screenshots, no manual cross-referencing.
Frequently asked
The December 2021 amendments substantially strengthened the technical-controls expectations: mandatory MFA for any NPI-containing system (Section 314.4(c)(6)), encryption for NPI at rest and in transit (Section 314.4(c)(3)), regular monitoring and testing (Section 314.4(d)), Qualified Individual oversight (Section 314.4(a)), and incident response planning (Section 314.4(h)). The amendments brought GLBA much closer to NYDFS and NIST 800-171 in technical specificity.
The FFIEC CAT is the supervisory examination tool federal banking regulators use to assess cybersecurity preparedness across five domains and five maturity tiers. CISGuard's continuous CIS benchmark scanning + multi-framework mapping produces the evidence base the CAT examiner walks through, with per-domain coverage reports that demonstrate the maturity tier the bank operates at.
Yes. The FTC enforces the Safeguards Rule against non-bank financial institutions including mortgage brokers, payday lenders, money transmitters, debt collectors, real-estate appraisers, and the broader FTC-regulated financial-services ecosystem. CISGuard's continuous evidence base supports the FTC Safeguards Rule examination process for all of these.
NY-licensed banks and financial institutions operate under both GLBA Safeguards Rule and NYDFS 23 NYCRR 500 simultaneously. The two frameworks substantially overlap; CISGuard's multi-framework mapping covers both from one CIS benchmark scan, with per-regulator report exports that satisfy each examiner's expected evidence format.
Section 314.4(a) requires designation of a Qualified Individual responsible for the information security program. CISGuard's executive-summary export, multi-framework dashboard, and trend analysis give the Qualified Individual the board-ready evidence the regulation expects, with the underlying control-by-control detail available for deep-dive on examination.
Use the original standards below to check terminology and requirements. These references explain the standards; they do not endorse CISGuard or independently verify its product coverage.
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