The Federal Trade Commission’s revised Safeguards Rule, which enumerates specific cybersecurity standards and procedures, will impose many new obligations on companies that are covered as “financial institutions” under the rule. These include new technical mandates and requirements to draft and implement specific kinds of written policies governing data security. With a November 9, 2022 compliance deadline, companies will need to begin planning for compliance now. We will discuss the new Rule and strategies that companies can take to manage new obligations.