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Cyber Security  

Our greatest threat

GLB Safeguarding - Disaster Recovery/Business Continuity
FACTA Red Flags - Breach Remediation - Remote Work

Safeguarding - Information Security/FACTA Red Flag/GLB Privacy/Remote Work/Disaster Recovery/Incident Response Safeguards Policy and Procedure Model Plan

Includes Disaster Recovery, Cybersecurity, Remote Work, Breach/Incident Remediation/Response, Business Continuity and Risk Assessment

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Compliance with 16 CFR section 314.4 - Safeguarding rules extended

The FTC enhanced rules surrounding Gramm-Leach-Bliley Safeguarding and entered them into the Federal Register Dec. 9, 2021, to go into effect December, 2022. We updated our model policies at that time. The agency gave another extension, until June, 2023, for the rules to go into effect, to allow industry to more time to prepare. 

States With Significant GLB Examinations
​

We have encountered significant examination requirements in New York, Massachusetts, Maryland, Virginia, Texas, Michigan. We have developed a rubric and draw a straight line to the GLB requirements within our model plan. 

NYS Department of Banking raises the bar on Cybersecurity - Our Product Meets the Requirements
Fannie Mae Requires NPI Policy - Not just what is required to be protected, but also how you will secure hardware

Information Security/Cybersecurity is Industry Hot Button

The FTC requires that all companies which handle sensitive consumer information implement a Red Flag ID Theft detection plan. We provide the Red Flag Plan, but also provide an information security plan and an employee training plan to make complying with the law simple. A company can't have a Red Flag rule if it doesn't already have an information security plan.  We have combined information security, mortgage origination, processing and closing with this Red Flag program to provide a comprehensive program that can actually be put into use. 
​
This is the ONLY information security/cybersecurity NPI and ID Theft Red Flags Plan available that is written specifically for the mortgage industry.

The Gramm-Leach-Bliley Act requires that all companies handling private consumer information have a Red Flag ID Theft detection plan in place.  We provide the Red Flag Plan, but also provide an information security plan and an employee training plan to make complying with the law simple.  Many states also require proof that lenders have an information security plan in place. If you are using a credit bureau to obtain consumer reports, you must also have an information security program under Fair Credit Reporting Act (FCRA) Requirements. 

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What is included

Procedures Specific to the Mortgage Industry
FACTA Required Red Flags Plan 
FCRA and GLB Required Safeguarding Plan
Risk Assessment

Employee Training Program Included
Working with Vendors (Risk Assessment)
Clean Desk Policy
Document Retention/Destruction
Safeguarding Private (non-public) NPI Data (GLB)
Red Flags in Origination
Remote Work Policy
Working with Borrowers
Breach/Incident Remediation and Reporting
Disaster Recovery/Business Continuity
​Risk Assessments
Red Flags in Processing
Closing/Funding Red Flags
Servicing Red Flags

Sample Table of Contents

2-9 IT Security GLB Safeguarding FACTA Disaster Recovery Remote Work
File Size: 7572 kb
File Type: pdf
Download File

Video edited on Kapwing

Purchase Information Security, FACTA Red Flag and ID Theft Plan

Price $395
Information Security Module is part of the Complete Banker or Correspondent Packs and Compliance Packs
Referred by a consultant, association, or wholesaler? Click here to request a discount code!
Download is delivered by e-mail link - allow 5-15 minutes for delivery
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All Material © 1996 - 2025 QuickStart Publications
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  • Home
    • Search our site
    • The CFPB and You
    • What Does a QC Plan Do?
    • Choosing the Right One
    • About Us >
      • Request Discount Code
      • About Us
      • Privacy Policy
      • Terms of Use
      • 100% Guarantee
      • Client List
    • Industry Blog
  • Single Policies
    • Single Policies
    • Free Sample Policies >
      • Free Sample Request Form
      • SAFE Act Policy
      • FREE Sample AML Plan
      • TIL-RESPA Integrated Disclosure (TRID)
      • Complaint Resolution
      • HPML Appraisal Policy
      • Social Media
      • Ability to Repay
      • E-Sign Policy
      • Loan Originator Comp
    • Disaster Recovery/Business Continuity Plan
    • Fair Lending/Fair Housing
    • Secondary Marketing-Loss Mitigation
    • Advertising
    • Anti-Money Laundering (AML/BSA/SAR) Plan
    • Appraiser Independence - Appraisal Management
    • Anti-Predatory Lending (UDAAP)
    • Vendor Management
    • Business Plan
    • MERS QA Plan
  • Modules
    • Module System
    • Mortgage Compliance Manual
    • Quality Control Options >
      • Quality Control Options
      • Lender Quality Control Plan >
        • HUD-FHA Quality Control Plan
      • Broker/Non-Del QC Plan
    • Information Security - FACTA/Red Flags & ID Theft >
      • IT/Cyber Audit
    • Origination/Production Module
    • Processing Module
    • Underwriting/Credit Policy
    • Closing/Funding/Warehouse
    • Mortgage Ops & Employee
    • Wholesale/Third Party Origination
    • Mortgage Servicing Module >
      • Mortgage Servicing
      • Mortgage Sub-Servicing
      • MERS Quality Assurance (QA)
  • Packages
    • Packages
    • Complete Mortgage Banker Package
    • Complete Correspondent Pack
    • Lender Compliance Pack
    • Broker-Non Del Compliance Pack
    • Processing Company Package
    • Anti-money laundering AML/BSA/SAR package >
      • Annual AML/BSA Audit
      • Annual AML Training
      • AML/BSA Plan
      • Free AML/BSA SAR Evaluation
    • Cyber/IT Security Audit Package >
      • Cyber Security Audit
      • IT/Cyber Security Training
      • CyberSecurity Policies
    • Advertising Audit Package
  • Services
    • Services
    • State Audit Prep >
      • State Audit Prep Package >
        • Georgia Mortgage Examination
        • Massachusetts Examination
        • Michigan Examination
        • Missouri Audit Prep
        • New York DFS License Exam
        • North Carolina NCCOB Examination
        • Ohio DFI License Examination
        • Pennsylvania Audit/Exam
        • Texas Exam Preparation
        • Washington DFI Exam
      • Annual Audit Preparation
      • State Examination System (SES) Support
      • State Examination Packages >
        • Supervisory Plan
    • Training Services >
      • Compliance Manager Training
      • AML Training
      • Social Engineering Phishing Training
      • Fair Lending Training
      • ID Theft Training FACTA
      • Cybersecurity Training GLB Safeguarding
      • Fraud Red Flag and QC Training
      • Appraiser Independence (AIR) Training
      • Privacy Act - GLB Training
      • Advertising Compliance Training
      • New Employee Training
      • RESPA Training
      • Truth-in-Lending Training
      • New York Human Rights Training
    • Knowledge Base
    • Audits/Reviews >
      • AML Audits
      • IT Security-Cyber Audits
    • Updates and Downloads >
      • Updates and Downloads
    • Warehouse Lender/Agency Approval >
      • Comergence Upload Service
    • Request Review
    • How to: Customization Services >
      • Customization Services
      • How to: Downloading Documents
      • How to: Customize Your Manual
      • Free "Generic" Customization Offer
  • Compliance Manager
    • My Compliance VP - Manager
    • Customer Portal