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IA filed comments with the FTC in response to its Safeguards Rule Workshop. IA is a strong proponent of reliable and effective data security programs. However, we noted that the proposed amendments to the Safeguards Rule would hinder the flexible, risk-based, and technology neutral approach that the FTC has been using for approximately the last two decades. IA believes that the current Safeguards Rule adequately regulates financial institutions and therefore such regulation should not be replaced with newer and more prescriptive requirements.