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FTC Safeguards Rule and MFA Compliance
The FTC Safeguards Rule, under the Gramm-Leach-Bliley Act (GLBA), now explicitly mandates Multi-Factor Authentication (MFA) for non-bank financial institutions. Organizations such as mortgage lenders, tax preparers, payday lenders and investment advisers must implement robust MFA mechanisms to protect sensitive customer data from credential-based breaches.
Who Needs to Comply?
All non-bank financial institutions handling sensitive customer data are required to adhere to the FTC Safeguards Rule. This extends to employees, contractors, service providers and customers accessing sensitive systems. The primary objective is safeguarding against unauthorized access through comprehensive MFA implementation.
What Constitutes MFA under the FTC Safeguards Rule?
MFA compliance requires at least two of the following authentication factors:
- Knowledge: Something you know (e.g., password)
- Possession: Something you have (e.g., hardware token)
- Inherence: Something you are (e.g., biometrics)
This multi-layered authentication approach substantially mitigates unauthorized access, particularly in scenarios involving compromised passwords.
Enforcement, Breach Notification and Comparison to Other Regulations
The FTC enforces the Safeguards Rule and mandates breach notification requirements. As of May 2024, institutions experiencing breaches involving unencrypted data affecting 500 or more consumers must report within 30 days. Crucially, breaches involving encrypted data still require reporting if encryption keys are compromised, underscoring the importance of secure key management through MFA.
Compared to other frameworks:
- HIPAA Security Rule: MFA is risk-based and not mandatory.
- NYDFS: Similar MFA requirements, but stricter with a 72-hour breach disclosure timeframe.
Building a Compliant Information Security Program (ISP)
To maintain compliance, organizations must establish and continually update their Information Security Program, supervised by a Qualified Individual. Essential ISP elements include:
- Regular risk assessments
- Robust access control and encryption
- Secure data disposal
- Continuous activity monitoring
- Frequent system testing
The ISP should adapt proactively to evolving cybersecurity threats and regulatory demands.
Advantages of Passkeys for MFA Compliance
Adopting passkey-based authentication offers numerous benefits that align with the FTC’s stricter standards:
- Eliminates passwords, significantly reducing operational costs (e.g., SMS OTP expenses)
- Enhances security through device-bound cryptographic keys
- Improves user experience via seamless biometric logins
- Simplifies third-party vendor compliance with integrated MFA
Early adoption positions institutions advantageously for future regulatory shifts and evolving customer security expectations.
Why Early Adoption Matters
Implementing passkeys now ensures current FTC Safeguards Rule compliance and future-proofs your organization against emerging cybersecurity risks and regulatory evolution. Solutions like Corbado provide real-time compliance monitoring, enabling organizations to maintain robust, continually improving security postures.
Conclusion: Embracing Robust MFA for Compliance
The updated FTC Safeguards Rule significantly strengthens cybersecurity obligations for non-bank financial institutions. MFA has become a fundamental requirement and transitioning to passkey solutions provides superior security, improved user experience and sustained compliance.
Explore detailed guidance on achieving seamless MFA compliance and the strategic benefits of passkey solutions on our dedicated blog post.
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