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Ethics & Fraudmedium18% of exam

At an FTC-regulated mortgage company, an originator sends a complete loan file, including tax returns and a Social Security number, to a personal email address to work at home. The mailbox is not approved and is outside the company’s information-security controls. Is sending the file there permitted under those safeguards?

Correct Answer

B) Prohibited: customer information leaves the safeguards program that way

B. The stated unauthorized transfer bypasses the company’s safeguards. Access for a work purpose does not authorize exporting sensitive information to an uncontrolled destination. A strong password addresses only part of security. It does not establish approved access, secure transmission, retention controls or oversight. Scope and exceptions: Do not generalize this to all remote work or claim every personal mailbox lacks every security control. An approved remote workflow is different. This item does not establish a breach-notification trigger. Source: Coverage; safeguards element c, access controls and encryption — https://www.ftc.gov/business-guidance/resources/ftc-safeguards-rule-what-your-business-needs-know

Answer Options
A
Permitted, because the originator is the person who assembled that whole file
B
Prohibited: customer information leaves the safeguards program that way
C
Permitted where the personal email account uses a strong password
D
Prohibited only if the email is intercepted and the data is misused

Why This Is the Correct Answer

B. The stated unauthorized transfer bypasses the company’s safeguards. Access for a work purpose does not authorize exporting sensitive information to an uncontrolled destination. A strong password addresses only part of security. It does not establish approved access, secure transmission, retention controls or oversight. Scope and exceptions: Do not generalize this to all remote work or claim every personal mailbox lacks every security control. An approved remote workflow is different. This item does not establish a breach-notification trigger.

Why the Other Options Are Wrong

Option A: Permitted, because the originator is the person who assembled that whole file

Assembling a file does not confer authority to move it anywhere.

Option C: Permitted where the personal email account uses a strong password

Password strength alone does not authorize the transfer.

Option D: Prohibited only if the email is intercepted and the data is misused

Safeguards are preventive; actual misuse need not occur first.

Exam Tip

Use approved channels for customer information, including when working remotely.

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