On August 2, 2019, BITS — the technology policy division of the Bank Policy Institute (BPI) — the American Bankers Association (ABA) and the Securities Industry and Financial Markets Association (SIFMA) submitted a comment letter to the Federal Trade Commission (FTC) in response to a notice of proposed rulemaking on the standards for safeguarding customer information.

The letter recommends that the FTC harmonize the remaining proposed amendments to its Safeguards Rule with the Federal Financial Institutions Examination Council (“FFIEC”) Interagency Guidelines Establishing Information Security Standards (“Interagency Guidelines”), rather than selecting and altering provisions from the New York Department of Financial Services (“NYDFS”) Cybersecurity Requirements for Financial Services Companies and the National Association of Insurance Commissioners (“NAIC”) Insurance Data Security Model Law. The letter also recommends that the FTC map its amendments to the industry-supported Financial Services Sector Coordinating Council (“FSSCC”) Cybersecurity Profile to allow cybersecurity professionals at covered firms to remain focused on the important work of identifying, managing, and mitigating data security risks, rather than on revising policies and procedures to align with the FTC’s revised regulations.