FTC Safeguards Rule Compliance for Mortgage & Real Estate Finance Firms

Mortgage brokers, lenders, and real estate finance firms are explicitly covered by the FTC Safeguards Rule due to their handling of borrower financial data.

Who This Applies To

• Mortgage brokers
• Residential and commercial lenders
• Real estate finance companies

What the FTC Safeguards Rule Requires

Covered firms must protect borrower data throughout the loan lifecycle, including application, underwriting, and servicing.

Written Information Security Program (WISP)

A mortgage-focused WISP documents how loan files, credit reports, and third-party data exchanges are secured.

Common Compliance Failures

• Emailing sensitive loan documents
• No vendor oversight of processors or escrow partners
• Outdated access controls
• No incident response planning

How RebootTwice Helps

We help mortgage and real estate finance firms implement safeguards that stand up to examiner review.