Section 501(b) of the Gramm-Leach-Bliley Act (GLBA) requires financial institutions to protect the security and confidentiality of customer information. How that requirement applies depends on your charter:
- Banks follow the Interagency Guidelines Establishing Information Security Standards, enforced by the OCC, FDIC, and Federal Reserve.
- Credit unions follow NCUA Part 748.
- Non-bank lenders and other financial companies fall under the FTC Safeguards Rule.
All three frameworks share the same core expectations. You must maintain a written information security program, assess risk across the systems that handle customer information, control access to that information, oversee your service providers, and dispose of customer data properly. The FTC Safeguards Rule adds explicit requirements to encrypt customer information in transit and at rest.
A multifunction printer (MFP) touches every one of those requirements. It scans account opening documents, prints loan disclosures, emails statements, and keeps copies of that data on internal storage. If a device handles customer information, it belongs in your risk assessment. Most institutions have never put it there.
Other regulations raise the stakes further. Publicly traded banks and holding companies must meet Sarbanes-Oxley (SOX) requirements for internal controls and record integrity, and Section 802 carries penalties for altering or destroying records improperly. Every state also has a data breach notification law, and some states go further. New York’s 23 NYCRR 500 cybersecurity regulation, for example, applies to the financial institutions it covers. A copier that exposes customer data can trigger notification duties the same way a compromised server does.