On October 27th, the Federal Trade Commission (“FTC”) finalized its long-awaited updates to the Safeguards Rule. The Safeguards Rule implements provisions of the Gramm-Leach-Bliley Act requiring the safeguarding of customer information, requiring a financial institution to develop, implement, and maintain a comprehensive written information security program appropriate to the size and complexity of the financial institution, the nature and scope of its activities, and the sensitivity of its customer information. Auto dealers and finance companies have always been subject to the requirements of the Safeguards Rule by virtue of offering credit transactions.

Originally published in Tennessee Dealer News, Winter 2022.