Cybercriminals are hoping you stop at compliance. They’re counting on your financial institution conducting a bare minimum GLBA or NCUA audit. This gives malicious actors a fairly easy “in” to breach your environment, steal customers’ non-public personal information (NPI), and sully your hard-earned community reputation.

This is why BAI’s Controls Audit goes far beyond just verifying your policies and procedures against regulatory compliance. We go the extra mile to examine your protocols in light of present-day best practices in IT security and emerging hacking methods that could compromise your environment. This is what we call BAI’s Compliance-PLUS Protection.


Our exhaustive Controls Audit verifies your institution’s existing controls against regulatory standards (GLBA or NCUA), as well as present-day banking best practices. As part of our audit process, BAI Security’s team of in-house compliance experts review the following key areas:

  • Management and IT Governance (including Cybersecurity Preparedness)
  • Development and Acquisition
  • Information Technology Operations
  • Electronic Payment Systems/Hosted and Managed Applications (including e-Banking)
  • 3rd Party Vendor Management
  • Business Continuity and Disaster Recovery (including Appendix J)


BAI Security takes the anxiety out of the controls audit process by evaluating current policies and procedures, and by performing a readiness assessment to see if your organization has met regulatory standards. We identify internal controls and policies to see if they work effectively to keep non-public information (NPI) safe and secure. In addition, we provide a gap analysis to identify issues unique to your environment, and we provide guidance on how your organization can become compliant.


With BAI’s comprehensive Controls Audit, you can implement the necessary changes to your information security programs and policies to keep customer information private. We provide customized analysis and guidance so you can reach compliance standards and have a written information security plan in place that adequately protects customer and consumer records. By abiding by the Safeguards Rule, your institution can build trust and confidence among your customers and community, as they are assured that their information will be secure.

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The Gramm-Leach-Bliley Act is a U.S. federal law created to control how financial institutions deal with a consumer’s non-public personal information (NPI). This is information that a financial institution collects when providing a financial product or service that can identify an individual and that isn’t otherwise publicly available.

  • The Privacy Rule, which regulates the collection and use of NPI
  • The Safeguards Rule, which requires financial institutions to implement a security program to protect NPI
  • Pretexting provisions, which prohibits access to NPI under false pretense
  • Ensuring the security and confidentiality of NPI
  • Protecting against unauthorized access which could cause substantial harm or inconvenience to any customer
  • Protecting against any threats which might affect the security or integrity of NPI

GLBA applies to all businesses, regardless of size, that are “significantly engaged” in providing financial products or services to consumers. This includes many companies not traditionally considered to be a financial institution such as check-cashing businesses, payday lenders, mortgage brokers, nonbank lenders, personal property or real estate appraisers, retailers that issue branded credit cards, professional tax preparers, and courier services. The law also applies to companies like credit reporting agencies and ATM operators that receive information about customers of other financial institutions. GLBA compliance is mandatory. Whether or not a financial institution discloses NPI, there must be a policy in place to protect the information from foreseeable threats in security and data integrity.

GLBA calls for severe civil and criminal penalties for noncompliance, including fines and imprisonment. If a financial institution violates GLBA, the following penalties may be issued:

  • The institution will be subject to a civil penalty of not more than $100,000 for each violation.
  • Officers and directors of the institution will be subject to, and personally liable for, a civil penalty of not more than $10,000 for each violation.
  • The institution and its officers and directors will also be subject to fines in accordance with Title 18 of the United States Code or imprisonment for not more than five years, or both.