FTC Safeguards Rule: Risk Assessment Checklist Explained

ftc safeguards risk assessment checklist

Dear Valued Customer,

The following minimal Risk Assessment Checklist is designed to swiftly gauge the extent to which your financial lending institution aligns with the newly enacted Federal Trade Commission (FTC) Safeguards Rule. This explanation aims to shed light on critical vulnerabilities that necessitate immediate attention for minimal compliance even before full checklist completion.

Foundational Cybersecurity Measures:

Lacking rudimentary security protocols exposes your enterprise to various cybersecurity risks, including unauthorized data access, malware, and data breaches. Below are essential safeguards that serve as the bedrock for protecting customer data, augmented by new mandates under the FTC Safeguards Rule.

The Triad of Basic Network Security:

  1. Static IP & Quality Firewall: Obtain a static IP address from your Internet Service Provider (ISP) and ensure the installation of a high-quality firewall router maintained by IT professionals. These are non-negotiable elements for securing remote access and deterring unauthorized entry, and failing to implement these leaves your data vulnerable to breaches.
  2. Restrict Web Access: Limit internet usage to business-critical websites and disable staff access to personal email and social media. Institutions implementing these measures have drastically reduced their vulnerability to malware, viruses, and productivity loss.
  3. IP Cameras: Numerous clients employ IP cameras across branches for internal security and to mitigate internal threats and fraud.

Elevating Security with FTC Safeguards Rule:

The FTC’s updated regulation mandates more than just robust network security; it now calls for proactive network monitoring. This entails using software tools that can log every keystroke across all workstations.

Additional Benefits:

Implementing these controls offers ancillary benefits, such as enhanced productivity tracking, particularly for remote staff. If your operations include remote access software—which should be rigorously secure—it’s crucial to maintain constant monitoring and updates to minimize data breach risks.

Next Steps:

This minimal Risk Assessment Checklist will pinpoint your most critical vulnerabilities immediately. The minimal checklist must be followed before a more thorough evaluation is completed. Should you have questions or desire a one-on-one call regarding any part of the compliance documentation, our years of experience uniquely position us to interpret these findings and guide you toward compliance with unparalleled efficacy.

We provide documentation outlining the steps to begin a phased FTC Safeguards Rule compliance. It’s essential to understand that implementing these steps is a separate service. We stand ready to assist in this implementation, drawing from our extensive expertise to facilitate a seamless transition to full compliance should you require assistance.

The list of vulnerabilities from our FTC Safeguards Rule: Starter Compliance Guide Chapter 12 is included. These are only some ways your network can be vulnerable, and without proactive monitoring, you may never even know you had a data breach. 

This compliance focuses on the technology side of FTC compliance. However, keep in mind there is a paper trail within the loan business that must also follow strict handling and disposal guidelines. Most customers should completely understand that part of keeping data safe and the cybersecurity requirements. 

If the first steps under Basic Network Security above have not been implemented

    • Static IP address
    • Firewall Router with External Website Access Restrictions
    • Email Restrictions
    • Employee Compliance Training
    • Network Monitoring Software

Your network does not meet the minimal requirements to be considered in compliance with the FTC Safeguards Rules, and steps must be taken to phase in compliance. The following list of vulnerability threats are possible without implementing all of the above as minimal steps for compliance.

For additional details or help enforcing compliance, please call us at 1-800-460-4600 or email helpdesk@unitetech.com to begin your fast track to FTC Safeguards Compliance. 

FTC Safeguards Rule: Starter Compliance Guide 

Chapter 12: Cybersecurity Vulnerabilities 

1. Internet Connection Vulnerabilities

  • Phishing Attacks: This is a method in which attackers masquerade as legitimate entities to trick users into revealing their personal information or login credentials.
  • Ransomware Attacks: Ransomware is malware that encrypts a victim’s files. The attacker then demands a ransom from the victim to restore access to the data.
  • Malware Attacks: These include various harmful software such as viruses, worms, trojans, and spyware, which can damage systems, steal data, or perform malicious operations.
  • DDoS Attacks: In a Distributed Denial of Service attack, multiple compromised computers are used to flood a system, causing it to become unavailable.
  • Man-in-the-Middle Attacks (MitM): Attackers intercept and potentially alter the communication between two parties without their knowledge.
  • SQL Injection: Attackers use malicious SQL code for backend database manipulation to access information not intended to be displayed.
  • Cross-Site Scripting (XSS): Attackers inject malicious scripts into websites viewed by users to bypass access controls.
  • Cross-Site Request Forgery (CSRF): An attack that forces an end user to execute unwanted actions on a web application where they’re authenticated.
  • Zero-Day Exploits: These are attacks that occur on the same day a weakness is discovered in software. At that point, it’s exploited before a fix becomes available from its creator.
  • DNS Tunneling: This is used to send non-DNS traffic over DNS protocols, which can be a method for data exfiltration or command and control in a network compromise.
    Brute Force Attacks: These are trial-and-error methods for obtaining information such as a user password or personal identification number (PIN).
  • AI-Powered Attacks: Attackers can now use AI to automate and increase the scale of their attacks.
  • IoT-Based Attacks: With the growing number of internet-connected devices, this attack vector is becoming more common.
  • Cloud Security Breaches: Inadequate measures can lead to unauthorized data exposure, account hijacking, or compromised services.
  • Software Vulnerabilities: Outdated software or systems that have not been patched can have vulnerabilities that cybercriminals can exploit.
  • Social Engineering: This involves manipulating people into giving up confidential information.

2. Email Vulnerabilities

  • Email Spoofing: This tactic is used in phishing and spam campaigns where the sender’s address and other parts of the email header are altered to appear as though the email originated from a different source.
  • Email Attachments: Malware can be delivered via email attachments. If an employee opens a malicious extension, the malware can infect the employee’s computer or the entire network.
  • Email Links: Phishing attacks often use email links to lead users to malicious websites where their information can be stolen.
  • Data Leakage via Email: Sensitive information might accidentally be sent to unauthorized recipients via email.
  • Drive-by Downloads: These happen when visiting a website, viewing an email message, or clicking on a deceptive pop-up window. Malware is downloaded and installed from an infected site to the user’s system without their knowledge.
  • Malvertising: This is the use of online advertising to spread malware. Malvertising attacks involve injecting malicious or malware-laden advertisements into legitimate online advertising networks and web pages.
  • Insecure or Compromised Websites: Visiting insecure (non-https) websites or websites that have been compromised can expose the user to various risks, including malware and data theft.
  • Cookies and Trackers: Many websites use cookies and other tracking technologies to profile users, which can infringe on privacy and potentially be misused.
  • Download of Unauthorized Software: Downloading software from non-work-related websites increases the risk of installing malicious software or violating copyright laws.
  • Social Media Threats: Scams, malware, and phishing attacks are common on social media platforms. Employees accessing these sites from work computers may inadvertently expose their systems to these risks.
  • Internet of Things (IoT) Devices: Many websites interact with IoT devices. If these websites are not secure, they can become a point of vulnerability.
  • Exploit Kits: These are software packages designed to identify software vulnerabilities and exploit them, often used in conjunction with malicious websites.
  • Content Spoofing: This technique involves creating a fake or shadow copy of an actual website or information. Users believe they’re on a legitimate site but are actually on a malicious one designed to steal their data or cause harm.
  • Credential Stuffing: Many people reuse their passwords. If employees use their work password on a non-work-related website that gets breached, their work systems could also be at risk.
ftc safeguards rule checklist