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Resource · Compliance

The FTC Safeguards Rule for tax and accounting firms

The Safeguards Rule, 16 CFR Part 314, is the federal rule behind the WISP requirement. Here is what it asks for, which parts small firms can skip, and which IT controls satisfy each element.

The nine elements, in plain English

Section 314.4 lists what an information security program must include. The right column shows the IT work that usually satisfies the technical side.

ElementWhat it asksIT that supports it
314.4(a)Name a Qualified Individual to oversee the programClear ownership; your IT provider can support but you stay responsible
314.4(b)Write a risk assessmentAsset inventory, network review, findings report
314.4(c)Put safeguards in place: access control, encryption, MFA, secure disposal, change management, loggingMFA, BitLocker, EDR, firewall, offboarding checklist, retention policy
314.4(d)Test or monitor the safeguardsContinuous monitoring, or annual penetration test and vulnerability scans every six months
314.4(e)Train your staffSecurity awareness training and phishing simulations
314.4(f)Oversee service providersVendor list, contracts, security questionnaires
314.4(g)Keep the program currentQuarterly reviews and change logs
314.4(h)Write an incident response planDocumented response steps, contacts and backups you can restore
314.4(i)Report to the board or owners at least yearlyAn annual written summary of the program

The small firm exemption

Under section 314.6, firms that maintain customer information on fewer than 5,000 consumers do not have to meet 314.4(b)(1) (a written risk assessment), 314.4(d)(2) (continuous monitoring or penetration testing), 314.4(h) (a written incident response plan) or 314.4(i) (the annual report). Most of the rule still applies, including MFA, encryption, training and vendor oversight.

Many small firms choose to do the exempt items anyway, because insurers and clients ask for them and they cost little once the rest is in place.

FTC notification

Since May 2024, firms must notify the FTC within 30 days of discovering a notification event involving unencrypted information of at least 500 consumers. Encryption is the single best way to keep a lost laptop from becoming a reportable event.

This page is a summary and is not legal advice. Read 16 CFR Part 314 and the FTC's guidance for the full requirements.

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