Mortgage cybersecurity: FTC Safeguards Rule compliance for brokers and lenders
The FTC Safeguards Rule hit mortgage companies hard in 2023. MFA is required. You need a qualified individual. Risk assessments are mandatory. And state regulators are paying attention. BlackSheep puts your entire compliance program in one place.
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Built by a CISSP with 20 years in financial services cybersecurity. 100+ compliance programs built. 100% clean exam record.
You already know the problem
The FTC Safeguards Rule changed the game in 2023. MFA, qualified individual, risk assessments, encryption. Most mortgage companies are still catching up.
Without BlackSheep
- FTC Safeguards Rule requirements with no system to track compliance
- MFA deployed inconsistently with no documentation
- No designated qualified individual or documented oversight
- State regulatory requirements varying by jurisdiction with no central view
- Borrower data protection relying on hope and IT provider promises
With BlackSheep
- Every FTC Safeguards Rule requirement mapped with live compliance scores
- MFA implementation tracked and documented across all systems
- Qualified individual designation with documented oversight activities
- Multi-framework compliance covering federal and state requirements
- Evidence collection and export for regulatory inquiries
Built for mortgage companies navigating the new rules
Every feature maps to what the FTC, state regulators, and cyber insurers expect to see.
Compliance Dashboard
See your FTC Safeguards, NIST CSF, and NYDFS 500 scores in one view. Know exactly where you stand on every requirement.
Policy Management
Information security policies mapped to FTC Safeguards Rule requirements. Version control, employee sign-offs, and renewal tracking.
Incident Response
Log incidents, track FTC notification requirements, and manage the full response lifecycle. Audit trails for every step.
Vendor Risk Management
Track every vendor that touches borrower data. Due diligence, risk assessments, contract terms, and ongoing oversight documented.
Access Control & MFA Tracking
Document MFA implementation across systems, track access reviews, and maintain evidence of the controls the FTC requires.
Risk Assessment
Written risk assessments as required by the FTC Safeguards Rule. Gap analysis, remediation tracking, and annual reviews.
Every framework that applies to your business
Mapped controls, tracked evidence, and live compliance scores for every regulation mortgage companies need to follow.
GLBA/FTC Safeguards Rule
The primary cybersecurity requirement for mortgage brokers and lenders. Amended in 2023 with significant new obligations.
- Designated qualified individual
- Written risk assessment
- Access controls and MFA requirement
- Encryption of customer information
- Incident response plan and FTC reporting
NIST CSF 2.0
The comprehensive cybersecurity framework that regulators reference.
- Govern — policies & roles
- Identify — asset management
- Protect — access control
- Detect — monitoring
- Respond & Recover
NYDFS 23 NYCRR 500
New York's cybersecurity regulation applies to licensed mortgage entities.
- CISO designation
- Annual penetration testing
- Multi-factor authentication
- Encryption requirements
- Annual certification filing
CIS 18 Controls
Prioritized security controls that strengthen your compliance posture.
- Asset inventory and control
- Secure configuration management
- Continuous vulnerability management
- Audit log management
- Incident response management
Everything your compliance program needs.
One platform, one price.
Our founder charged $30,000/year per firm to build these programs by hand. Now it's all in software.
DIY
Save $36,000+/year on compliance costs
The full platform. Every feature. Every framework. No gates. Whether you self-manage or work with a consultant, everything is in one place.
- All compliance frameworks
- Live compliance dashboard & scores
- Policy templates & sign-offs included
- Vendor risk management & oversight
- Risk assessment with gap analysis
- Access reviews & IT controls review
- Incident tracking with breach timers
- IR & BCP testing logs
- Security training & tracking
- Cyber insurance readiness
- Tasks, scheduling & annual reporting
- Unlimited users
- Email support
Builder
Hands-on services included
Everything in DIY, plus we do the hands-on work. Incident response testing, business continuity testing, audit support, and annual training included.
- Everything in DIY
- We lead your incident response testing
- We lead your business continuity testing
- We provide audit support
- We lead your annual security training
Professional
Your fractional compliance team
Everything in Builder, plus we're alongside you week to week. Still less than a single consulting engagement.
- Everything in Builder
- Biweekly calls to lead your compliance program
- We will personally guide you through the full implementation of your cybersecurity program
- The Maverick to your Goose
- We have your back
All plans include a 14-day free trial. No credit card required. Cancel anytime.
Ready for compliance in 30 days or we extend your trial free until you are.
Frequently asked questions
What compliance frameworks does BlackSheep support for mortgage companies?
BlackSheep supports the GLBA/FTC Safeguards Rule (the primary cybersecurity requirement for mortgage brokers and lenders), NIST Cybersecurity Framework 2.0, NYDFS 23 NYCRR 500 for New York-licensed entities, and CIS 18 Critical Security Controls.
What are the key FTC Safeguards Rule requirements for mortgage companies?
The amended FTC Safeguards Rule requires designating a qualified individual, conducting written risk assessments, implementing access controls and MFA, encrypting customer information, developing an incident response plan, and reporting security events. BlackSheep maps and tracks all of these requirements.
Does BlackSheep help with the MFA requirement?
Yes. BlackSheep tracks your MFA implementation across systems and applications, documents which systems require MFA, and maintains evidence of compliance for the FTC Safeguards Rule MFA requirement.
What is the qualified individual requirement and how does BlackSheep help?
The FTC Safeguards Rule requires you to designate a qualified individual to oversee your information security program. BlackSheep helps you document this designation, track oversight activities, and maintain evidence that this requirement is being met.
Do we need to comply with NYDFS 500 if we're licensed in New York?
If your mortgage company is licensed by the New York Department of Financial Services, you likely need to comply with 23 NYCRR 500. BlackSheep maps all NYDFS 500 requirements alongside the FTC Safeguards Rule so you can manage both from a single dashboard.
Your compliance frameworks
GLBA/FTC Safeguards Rule
FTC requirements for non-bank financial institutions handling customer data
NIST CSF 2.0
The gold standard cybersecurity framework for risk management
NYDFS 500
New York cybersecurity regulation for licensed financial services companies
CIS 18 Controls
Prioritized security controls for mortgage lenders and servicers
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The FTC Safeguards Rule isn't going away. Get compliant.
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