If you are a Title IV institution, compliance with the revised
Safeguards Rule and implementation of the data security controls
set forth in the revised Rule is now a required segment of your
annual financial audit.
The Federal Trade Commission's (FTC) amendment to the
Safeguards Rule under the Gramm-Leach-Bliley Act (GLBA) became
effective on June 9, 2023. The comprehensive amendment updated data
security requirements for financial institutions, including all
Title IV institutions of higher education. The U.S. Department of
Education has increased enforcement authority by requiring auditors
to verify an institution's compliance with components of the
Safeguard Rule.
In March, the U.S. Department updated the Guide for
Financial Statement Audits of Propriety Schools and For Compliance
Attestation Examination Engagements of Proprietary Schools and
Third-Party Servicers Administering Title IV Programs
(“Audit Guide”). The Audit Guide is effective for
fiscal years