On November 7, 2016, BITS — the technology policy division of the Bank Policy Institute (commonly referred to as “BPI,” formed in 2018 following the merger of The Clearing House Association and the Financial Services Roundtable) — submitted comments to the Federal Trade Commission (FTC) as part of the FTC’s systematic review of all current Commission regulations and guides.

The letter comments on three areas: (1) the importance of maintaining the provisions of the Safeguards Rule as is; (2) the importance of harmonizing the Safeguards Rule with the NIST Cybersecurity Framework; and (3) the need to preserve the scope of the term “financial institution” as currently espoused in the Rule.