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Can leadership be held personally responsible for failure to comply with GLBA?

Yes, to varying degrees.

Under the Financial Services Modernization Act (GLBA) a Director or Officer of a financial institution can be incarcerated for as long as five (5) years and fined up to $10,000 for failure to comply with the regulation. 

Typically speaking organizations that have strong written and documented procedures, policies, employee training, and vendor due diligence practices will be subject to lessor consequences for failure to comply with GLBA and other regulations. 

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