On April 4, 2019 the Federal Trade Commission (FTC) requested comment on its proposal to amend the Standards for Safeguarding Customer Information (safeguard rule). While banks are generally not subject to FTC authority, they are affected by the safeguard rule through service providers. As such, WBA filed comments on Aug. 2, 2019 recommending that FTC follow the Federal Financial Institutions Examination Council's Guidelines in order to set risk-based standards. WBA highlighted flexibility as a necessity in enhanced efforts in the realm of data security.

Read the full comment letter.