On October 27, 2021, the Federal Trade Commission (FTC) revised the Gramm-Leach-Bliley Act (GLBA) Safeguards Rule (“Revised Rule”) for the first time since the rule was issued in 2002. The Safeguards rule requires certain financial institutions to implement a written information security program (“ISP”) to protect consumer financial information as well as conduct periodic risk assessments to make sure the organization is abiding by strict protocols to protect this information.