Title V of the Gramm-Leach-Bliley Act governs how financial institutions handle consumer non-public personal information. It has three parts: the Privacy Rule on notices and information sharing, the Safeguards Rule requiring a written information security programme, and the Pretexting provisions. For fintechs the Safeguards Rule is the operative one, since the FTC's amended version applies to non-bank financial institutions and carries prescriptive security requirements.