GLBA
U.S. law for financial privacy notices and safeguards
MAS TRM
Singapore guidelines for financial technology risk management
Quick Verdict
GLBA mandates US financial privacy notices and NPI safeguards for broad non-banks, while MAS TRM provides proportionate tech risk guidelines for Singapore FIs. Organizations adopt GLBA for legal compliance, MAS TRM for supervisory resilience.
GLBA
Gramm-Leach-Bliley Act (GLBA)
Key Features
- Mandates privacy notices and opt-out for NPI sharing
- Requires written risk-based information security program
- Applies to broad non-bank financial institutions
- Designates Qualified Individual with board reporting
- Imposes 30-day FTC breach notification rule
MAS TRM
MAS Technology Risk Management Guidelines
Key Features
- Board and senior management accountability for oversight
- Proportional controls based on asset criticality and risk
- Third-party risk management beyond formal outsourcing
- Defence-in-depth cyber resilience requirements
- Annual penetration testing for internet-facing systems
Detailed Analysis
A comprehensive look at the specific requirements, scope, and impact of each standard.
GLBA Details
What It Is
The Gramm-Leach-Bliley Act (GLBA), enacted in 1999, is a U.S. federal regulation establishing privacy and security standards for financial institutions handling nonpublic personal information (NPI). It focuses on transparency in data sharing and risk-based safeguards, implemented via the Privacy Rule (16 C.F.R. Part 313) and Safeguards Rule (16 C.F.R. Part 314).
Key Components
- **Privacy RuleInitial/annual notices, opt-out rights for nonaffiliated sharing.
- **Safeguards RuleWritten security program with administrative, technical, physical controls; Qualified Individual designation; annual board reporting; vendor oversight.
- **Pretexting protectionsAnti-social engineering measures. No fixed control count; risk-based with recent prescriptive elements like breach notification.
Why Organizations Use It
- Mandatory for broad financial entities (banks, non-banks like tax firms, auto dealers).
- Mitigates enforcement risks (fines up to $100K/violation), builds customer trust, enhances cybersecurity resilience, supports vendor management.
Implementation Overview
Phased approach: scoping, risk assessment, policy development, technical controls (encryption, MFA), training, testing. Applies to U.S. financial activities; FTC enforces for non-banks. Ongoing audits, no formal certification.
MAS TRM Details
What It Is
MAS Technology Risk Management (TRM) Guidelines (January 2021) are supervisory guidelines issued by Singapore's Monetary Authority (MAS) for financial institutions. They provide a principles-based framework for governing technology and cyber risks, emphasizing proportional implementation based on risk profile, complexity, and criticality to ensure CIA (confidentiality, integrity, availability).
Key Components
- 15 sections covering governance, risk frameworks, secure development, IT operations, resilience, access controls, cryptography, cyber defense, assessments, and audit.
- Synthesized 12 core principles like board accountability, asset classification, third-party oversight.
- No fixed controls; focuses on outcomes with independent assurance.
Why Organizations Use It
- Meets MAS supervisory expectations to avoid enforcement.
- Enhances resilience, reduces cyber incidents, builds trust.
- Supports digital transformation securely.
Implementation Overview
- Risk-based rollout: asset inventory, control mapping, testing.
- Applies to all MAS-supervised FIs; scalable by size.
- No certification; evidenced via audits, metrics, board reports. (178 words)
Key Differences
| Aspect | GLBA | MAS TRM |
|---|---|---|
| Scope | Consumer financial privacy, NPI security program | Comprehensive technology/cyber risk management |
| Industry | US financial institutions (broad non-banks) | Singapore financial institutions (all sectors) |
| Nature | Federal law with FTC rules, mandatory compliance | Supervisory guidelines, proportionate implementation |
| Testing | Vulnerability/penetration testing, risk assessments | Annual PT for internet systems, regular VA/DR tests |
| Penalties | Civil penalties up to $100k/violation, imprisonment | Supervisory actions, fines, license conditions |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about GLBA and MAS TRM
GLBA FAQ
MAS TRM FAQ
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