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Dreher Tomkies LLP
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2750 Huntington Center
41 South High Street
Columbus, Ohio 43215
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FTC TO OFFER TRAINING PROGRAMS RELATING TO SAFEGUARDING CUSTOMER FINANCIAL INFORMATION

The Federal Trade Commission announced that it will offer two training programs for financial institutions that are subject to its Safeguarding of Customer Financial Information Rule. "Financial institutions" subject to the FTC's jurisdiction for purposes of the Gramm-Leach-Bliley Act ("GLBA") must implement an information security program pursuant to the FTC rule on safeguarding customer information no later than May 23, 2003. Financial institutions subject to the FTC's jurisdiction include mortgage lenders, payday lenders, finance companies, mortgage brokers, non-bank lenders, check cashers and collection agencies.

The objectives of these standards are to: ensure the security and confidentiality of customer records and information, protect against any anticipated threats or hazards to the security or integrity of such records and protect against unauthorized access to, or use of, such records or information that could result in substantial harm or inconvenience to any customer.

Under the rule, financial institutions must:

  • Designate an employee or employees to coordinate its information security program;
  • Identify reasonably foreseeable internal and external risks to the security, confidentiality and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction or other compromise of such information, and assess the sufficiency of any safeguards in place to control these risks;
  • Design and implement information safeguards to control the risks identified and regularly test or otherwise monitor the effectiveness of the safeguards;
  • Taking reasonable steps to select and retain service providers that are capable of maintaining appropriate safeguards for the customer information at issue; and
  • Evaluate and adjust information security programs as necessary due to material changes to operations or other relevant circumstances.

The FTC announced that the training program will be offered on two dates: June 9, from 10-11 a.m., and June 23, from 2-3 p.m. Both sessions will be held in Washington, DC. The sessions are open to the public and there is no advance registration. For more information on the Safeguards Training program, the FTC asked that interested parties contact Laura Berger or Ellen Finn at (202) 326-3224.

Mike Tomkies and Elizabeth Anstaett