Which is why most organizations inside the definition have never been told they're in it. This walks you through what you would be able to show, in about five minutes.
The Governance Proof Status™ is an educational self-assessment tool. It is not legal advice, not a legal opinion, and not a regulatory audit, examination, or certification. It does not create an attorney–client relationship, and it does not determine or guarantee compliance with the FTC Safeguards Rule (16 CFR Part 314) or any other law, rule, or regulation.
Your status reflects only the answers you provide. It is a directional indicator based on self-reported information, not an independent verification of your organization's practices, controls, or records. Regulatory requirements vary by organization and change over time.
No result — of any color or value — should be relied upon as assurance that your organization is or is not compliant, or as a substitute for advice from qualified legal counsel or a licensed professional regarding your specific circumstances. Always consult your own counsel before making decisions with legal or regulatory consequences.
By continuing, you acknowledge that you are using this tool for informational and educational purposes only.
There is no wrong answer here. It only decides how the next few minutes are framed.
Here's the part that surprises people. Under the Gramm-Leach-Bliley Act framework the Safeguards Rule sits in, a financial institution is any business significantly engaged in activities that are financial in nature, or incidental to financial activities.
The FTC has stated that businesses which finance, or facilitate the financing of, purchases for consumers are financial institutions for purposes of the Rule, because lending money is a financial activity. Leasing personal property on a non-operating basis for longer than 90 days is treated the same way.
So an organization can send every credit application to an outside lender, hold no paper of its own, never call itself a lender, and still sit inside the definition.
16 CFR §314.2(h), definition of financial institution. Coverage depends on your organization's own facts; nothing here determines it for you.
Understood. If that is accurate, the Rule may genuinely not reach your organization. We're not going to invent a reason it does.
One question before you go, because it is the one that catches people:
Does anyone at your organization take information from a consumer, such as an application, income details, or a Social Security number, and pass it to a lender, leasing company, or financing partner?
Then this instrument probably isn't for you, and that's a good outcome. You spent a minute and learned where the boundary sits, which is more than most organizations on either side of it can say.
If that ever changes, whether through a new financing partner, a lease program, or an acquisition, the boundary moves with the activity and not with your industry.
That is defined by what an organization does. Arranging or extending credit, leasing on a non-operating basis beyond 90 days, servicing or collecting on consumer accounts, or otherwise handling consumers' financial information as part of providing a financial product or service.
In practice that has included auto, RV, marine, and powersports dealers; independent finance and leasing companies; mortgage brokers; tax preparation firms; and collection agencies.
Enter your details to see your status, your strengths, and your next proof.
Your responses stay private. We'll only use your email to send your results and follow up if you ask us to.
This status shows you where your evidence stands. It does not yet show you why each element is written the way it is, or what your own answers mean when read together.
That is the Governance Evidence Review. It is a scheduled walkthrough where we go through your twenty-one answers with you, in your own words, and explain what the Rule is actually asking for behind each one. You leave with three honest paths for what to do next, and you choose among them. Nothing is recommended to you until you've seen the reasoning that produced it.
It is a conversation, not a presentation. You will be asked to reach your own conclusions, and there is no obligation attached to any of them.
Your full results, walked through with you · no cost, no obligation