We explore the affect of the FTC’s proposed amendments to the GLBA Privacy Rule, which affects only motor vehicle dealers, and the broader GLBA Safeguards Rule, which applies to all non-bank financial institutions under FTC jurisdiction.  The FTC has shifted from a flexible approach to data security to a more prescriptive one that mandates specific elements for information security programs.  We will discuss the potential impact of this shift and opportunities for companies to influence the final rules.