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GLBA Safeguards Auditor

11 of 17 applicable Safeguards Rule elements have gaps; 4 are priority 1: 16 CFR 314.4(c)(3), (c)(5), (h) and (j).

Evidence · Safeguards questionnaire

314.4(b),Yes,"Written risk assessment with likelihood and impact criteria, approved by the board",D. Whitfield,2025-05-24

Working

Last performed 2025-05-24, 16 months before the 2026-09-24 review; 314.4(b) is due at least every 12 months (the risk assessment refresh setting), so the oldest date that passes is 2025-09-24. Priority: tier 2 weight 2 x gap weight 2 = 4 (3 to 5 is P2).

Method

1Each element of 16 CFR 314.4 (a) through (j), including (d)(1), is tested against the questionnaire; missing elements are gaps.

2No, partial and yes-without-evidence answers are gaps; n/a is accepted only for (c)(4) secure development.

Photo: David Trinks, Unsplash

Gaps · Across 16 CFR 314.4

Element	Title	Status
16 CFR 314.4(b)	Written risk assessment	Gap
16 CFR 314.4(c)(2)	Data and systems inventory	Gap
16 CFR 314.4(c)(3)	Encryption in transit and at rest	Gap

Reads

Safeguards control questionnaire answers

Produces

Element-by-element gap report and a remediation plan (Safeguards Rule gap report, Remediation plan (11 steps), Element results (CSV))

Price

$3,000 / month, 30% to the referring partner

Your files

Read in memory for the session, never stored, never used to train a model.

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Not financial, investment, banking or securities advice. Filings and screening results must be reviewed by a qualified compliance professional. Privacy and security findings are not legal advice or an audit opinion. Confirm them with privacy counsel or a qualified assessor.