GLBA
U.S. law for financial privacy notices and safeguards
FedRAMP
U.S. government program standardizing federal cloud security authorization.
Quick Verdict
GLBA mandates privacy notices and security for financial firms handling NPI, enforced by FTC with hefty fines. FedRAMP authorizes secure cloud services for federal use via NIST controls and 3PAO audits. Firms adopt GLBA for compliance, FedRAMP for government contracts.
GLBA
Gramm-Leach-Bliley Act of 1999
Key Features
- Requires privacy notices and opt-out rights for NPI sharing
- Mandates written information security program with safeguards
- Broad activity-based financial institution definition
- Designates Qualified Individual for oversight and reporting
- 30-day FTC breach notification for 500+ consumers
FedRAMP
Federal Risk and Authorization Management Program
Key Features
- Assess once, use many times reusability model
- NIST SP 800-53 Rev 5 baselines at three impact levels
- Independent third-party assessments by accredited 3PAOs
- Continuous monitoring with monthly/quarterly deliverables
- FedRAMP Marketplace for authorized cloud services
Detailed Analysis
A comprehensive look at the specific requirements, scope, and impact of each standard.
GLBA Details
What It Is
Gramm-Leach-Bliley Act (GLBA) is a U.S. federal regulation enacted in 1999 for financial modernization. It mandates privacy protections and security for nonpublic personal information (NPI) via Privacy Rule and Safeguards Rule, using a risk-based approach.
Key Components
- **Privacy Rule (16 C.F.R. Part 313)Initial/annual notices, opt-out for nonaffiliated sharing.
- **Safeguards Rule (16 C.F.R. Part 314)Comprehensive security program with 9 elements including risk assessment, access controls, encryption, vendor oversight, Qualified Individual.
- **Pretexting provisionsBans false pretenses access. No formal certification; enforced via FTC audits.
Why Organizations Use It
- Mandatory for financial institutions to avoid $100k+ penalties.
- Builds customer trust, reduces breach risks, ensures vendor accountability.
- Enhances reputation, supports compliance with state laws.
Implementation Overview
Phased: scoping NPI flows, risk assessment, policy/training, technical controls (MFA, encryption), testing, board reporting. Applies broadly to banks, tax firms, auto dealers; ongoing for all sizes with annual reviews.
FedRAMP Details
What It Is
FedRAMP (Federal Risk and Authorization Management Program) is a U.S. government-wide framework standardizing security assessment, authorization, and continuous monitoring of cloud services for federal agencies. Its risk-based approach uses NIST SP 800-53 Rev 5 controls tailored to FIPS 199 impact levels (Low, Moderate, High, LI-SaaS).
Key Components
- Baselines with ~156 (Low), ~323 (Moderate), ~410 (High) controls.
- Core artifacts: SSP, SAR, POA&M, continuous monitoring plans.
- Built on NIST standards; requires 3PAO independent assessments.
- Authorization via Agency or Program paths, listed in Marketplace.
Why Organizations Use It
- Unlocks federal contracts ($20M+ potential).
- Mandatory for CMMC-compliant federal cloud procurement.
- Enhances risk management, reusability ("assess once, use many").
- Builds trust, differentiates in commercial markets.
Implementation Overview
- 12-18 month process: categorization, documentation, 3PAO assessment, remediation.
- Applies to CSPs targeting U.S. federal market; high resource needs.
- No formal certification; ongoing continuous monitoring required.
Key Differences
| Aspect | GLBA | FedRAMP |
|---|---|---|
| Scope | Consumer financial privacy and security | Cloud service security assessment |
| Industry | Financial institutions (broad non-banks) | Cloud providers serving federal agencies |
| Nature | Mandatory U.S. regulation with FTC enforcement | Standardized authorization program |
| Testing | Risk assessments, pen testing, vulnerability scans | 3PAO assessments, continuous monitoring |
| Penalties | $100k per violation, criminal penalties | Loss of authorization, contract ineligibility |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about GLBA and FedRAMP
GLBA FAQ
FedRAMP FAQ
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