The FTC's updated Safeguards Rule (16 CFR Part 314) applies to a broader range of "financial institutions" than most people expect — mortgage brokers, auto dealers that finance vehicles, tax preparers, and investment advisers not otherwise regulated, alongside banks — and explicitly requires annual penetration testing or continuous monitoring, plus biannual vulnerability assessments, as part of a documented information security program.
We deliver the testing component that requirement calls for, reported for direct inclusion in your program documentation.
We scope penetration testing to the systems handling customer financial information to satisfy §314.4(d)(2)'s testing requirement, and review the access controls, encryption and vendor oversight the broader Safeguards Rule information security program requires alongside it.
Why it matters
The updated Safeguards Rule, with enforcement beginning in 2023, brought many non-bank financial institutions into scope for the first time, and the FTC has shown it will enforce. A documented, current testing program is the clearest way to demonstrate the "comprehensive information security program" the rule actually requires.
What we test
- Customer information systems penetration testing (§314.4(d)(2))
- Biannual vulnerability assessment
- Access control & authentication testing
- Encryption of customer information — implementation review
- Service provider / vendor oversight review
- Information security program evidence package
Common vulnerabilities we uncover
- No documented annual penetration test or continuous monitoring program
- Missing biannual vulnerability assessment
- Customer financial information inadequately encrypted at rest or in transit
- Vendors and service providers with unreviewed access
- No qualified individual formally designated to oversee the program
- Insufficient evidence of a comprehensive information security program
Our methodology
- Scoping & rules of engagement. We agree objectives, targets and boundaries for your glba safeguards rule penetration testing, so testing is safe, authorized and focused on what matters to your business.
- Reconnaissance & mapping. We enumerate the full attack surface in scope, building a complete picture before any exploitation begins.
- Manual exploitation. Our senior testers chain vulnerabilities by hand — going far beyond automated scanners — to prove real, demonstrable impact.
- Analysis & reporting. Every finding is triaged, risk-rated with CVSS and written up with a copy-paste reproduction and clear remediation.
- Remediation support & free retest. We support your team through the fixes and retest the remediated issues to confirm they are genuinely closed.
Tools & techniques
We test the systems handling customer financial information to satisfy §314.4(d)(2), combined with a review of encryption at rest and in transit, access controls, and oversight of vendors and service providers who touch customer data on your behalf.
When you need this engagement
- You are a non-bank financial institution newly in scope under the updated Safeguards Rule
- Your annual penetration test or continuous monitoring is due
- You need vulnerability assessment evidence for your information security program
- A partner or regulator has requested evidence of Safeguards Rule compliance
- You are building your information security program from scratch
What you receive
- Penetration test report satisfying §314.4(d)(2)
- Biannual vulnerability assessment documentation
- Access control & encryption findings
- Vendor oversight review
- Information security program evidence package
- Free retest after remediation
What’s included in your report
Every glba safeguards rule penetration testing engagement concludes with a comprehensive, board-ready report and a working session to walk your team through it. Your report includes:
- An executive summary with overall risk posture for non-technical stakeholders
- Detailed technical findings, each with a step-by-step, copy-paste reproduction
- CVSS v3.1 severity ratings and business-impact context for every issue
- Prioritized, actionable remediation guidance your engineers can apply directly
- A complimentary retest to confirm fixes and update finding status
- A formal attestation letter for customers, auditors and compliance programs
Standards & frameworks
GLBA Safeguards Rule (16 CFR Part 314)
FTC guidance
Outcomes you can expect
After your glba safeguards rule penetration testing, you will have clear, evidence-based visibility into your real security risk — not a scanner’s guesswork. You will know exactly which weaknesses an attacker could exploit, what the business impact would be, and the precise steps to fix them in priority order. Teams use our findings to close critical gaps, satisfy customer and regulator security requirements, and demonstrate due diligence to their board. With a complimentary retest included, you also get documented proof that the issues are genuinely resolved.
Engagement details & logistics
Every glba safeguards rule penetration testing starts with a short, no-obligation scoping call to understand your goals, environment and constraints, followed by a fixed-price proposal and a clear statement of work. Most engagements are delivered fully remotely, with on-site work arranged where it genuinely adds value. Throughout testing we maintain an agreed communication cadence and escalate any critical, high-impact finding to you immediately rather than waiting for the final report. All work is performed under a signed NDA with strict data-handling controls, using safe, non-disruptive techniques and carefully coordinated rules of engagement to protect your production systems. On completion you receive your report and a walkthrough session, followed by a complimentary retest once your fixes are in place. Typical engagements are booked one to three weeks in advance, and urgent or pre-deadline testing can often be accommodated — just ask at hi@agentoffense.com.
Why organizations choose AgentOffense
Our glba safeguards rule penetration testing is delivered by senior offensive-security engineers who test the way real attackers do — manually, creatively and with a relentless focus on proving genuine, demonstrable impact. Here is what sets our engagements apart:
- Manual, exploit-driven testing that chains vulnerabilities the way a real attacker would, going far beyond what automated scanners can find.
- Reproducible proof for every finding, with copy-paste reproduction steps your engineers can follow and independently verify.
- Honest severity calibration so you invest in fixing what genuinely matters and avoid wasting effort on false positives and noise.
- Clear, business-focused reporting that speaks to engineers and executives alike, tying every issue to real-world impact.
- A complimentary retest included, so you get documented proof that your fixes actually close the attack path.
- Responsible, collaborative delivery with a named point of contact and secure handling of all data throughout the engagement.
Explore related services
GLBA Safeguards Rule Penetration Testing is frequently scoped alongside our other offensive-security services for broader coverage. Explore related engagements that complement it:
How much does GLBA Safeguards Rule Penetration Testing cost?
Every glba safeguards rule penetration testing is scoped and priced individually, so you pay for exactly the coverage you need — with no hidden extras. After a short, no-obligation scoping call we send a fixed-price quote, usually within one business day, with clear deliverables, a firm timeline and a complimentary retest included. The price of your glba safeguards rule penetration testing depends on the size and complexity of the target and the depth of testing required, so you always know the cost up front before any work begins.
Get a fixed-price quote
Frequently asked questions
Does GLBA require penetration testing?
Yes. The FTC's updated Safeguards Rule, 16 CFR §314.4(d)(2), explicitly requires annual penetration testing or continuous monitoring, plus biannual vulnerability assessments, as part of your information security program.
Who counts as a "financial institution" under the Safeguards Rule?
A broader group than most people expect: mortgage brokers, auto dealers that finance vehicles, tax preparers, investment advisers not otherwise regulated, and other non-bank entities handling customer financial information, not just banks.
What changed with the updated rule?
The updated Safeguards Rule, with enforcement beginning in 2023, added explicit testing, encryption, access-control and vendor-oversight requirements, and requires a qualified individual to oversee the information security program.
How does this relate to NYDFS?
They overlap for financial institutions in both scopes, and we can align a single testing engagement to satisfy both GLBA and NYDFS evidence requirements where applicable.