The FFIEC retired its Cybersecurity Assessment Tool in August 2025. The NCUA released an updated ACET aligned with NIST Cybersecurity Framework 2.0. The Homebuyers Privacy Protection Act passed in September 2025 and takes effect March 2026. If your compliance documentation still references the old FFIEC CAT framework, you are already behind.
Compliance in mortgage lending is not a once-a-year exercise. It is a daily operational requirement that touches every aspect of your Microsoft 365 tenant. How you manage user access, protect borrower data, configure devices, and monitor for threats. Each of these is both a security control and a compliance obligation.
ABT's Guardian operating model treats compliance as a byproduct of strong security operations. The same nightly scans that detect MFA gaps and stale accounts produce the evidence your examiner needs. No separate compliance workflow. No last-minute scramble before the audit.
Mortgage lenders operate under overlapping regulatory frameworks that multiply compliance complexity. Here is what your institution needs to address:
Manual compliance processes fail at three predictable points:
Evidence collection takes too long. When the auditor asks for proof that MFA is enforced across all accounts, someone exports a report from Entra ID, formats it in Excel, adds explanatory notes, and emails it. This takes hours for a single control. Multiply by dozens of controls across multiple frameworks, and you are looking at weeks of preparation for each examination.
Point-in-time evidence goes stale. The report you pulled on Monday is outdated by Wednesday. A new user was provisioned without MFA. A device fell out of compliance. A Conditional Access exclusion was created for a vendor integration. Manual evidence is a snapshot that does not reflect current state.
Multiple frameworks create redundant work. GLBA, FTC Safeguards Rule, NIST CSF 2.0, NYDFS, and GSE requirements all ask for overlapping evidence. MFA enforcement is required by all of them. Without a unified system, your team documents the same control five different ways for five different audiences.
Guardian produces compliance evidence as a natural output of its security monitoring operations. This is not a compliance-specific feature bolted onto a security tool. It is the same data, organized for different audiences.
Every night, Guardian scans your Microsoft 365 tenant and records the state of your security controls. MFA enrollment status for every user. Device compliance status for every endpoint. Conditional Access policy configuration and any exclusions. DLP policy status and violation patterns. External sharing configurations.
This data is stored with timestamps. When your examiner asks for evidence at any point in time, the data exists. You do not reconstruct it from memory or partial logs.
Guardian's findings map to multiple regulatory frameworks simultaneously. A single MFA enforcement report satisfies:
Your team pulls one report. The data answers questions from five different regulatory frameworks.
Guardian does not just tell you what you have implemented. It tells you what is missing. Each gap includes:
This turns compliance from a checklist exercise into a prioritized action plan. Your team knows what to fix first, why it matters, and how to do it.
ABT's clients do not prepare for audits. They are always prepared. Guardian's reporting produces documentation that auditors and examiners expect to see:
When the examiner calls, your IT director does not cancel their afternoon meetings. They pull the reports and send them.
Compliance in Guardian follows the same four-stage lifecycle as security operations: Harden, Monitor, Insight, Respond.
ABT configures your Microsoft 365 tenant to meet the requirements of every applicable regulatory framework from day one. Conditional Access enforces MFA. DLP policies protect borrower data. Email authentication prevents spoofing. Device compliance ensures only managed endpoints access your environment.
The hardened baseline is documented. Each policy maps to the regulatory requirement it satisfies. This documentation becomes the foundation of your compliance evidence package.
Compliance drift is the silent killer. A well-configured tenant today becomes non-compliant tomorrow when someone creates an exclusion, modifies a policy, or provisions a user outside the standard process.
Guardian detects drift within 24 hours. Each drift event is logged with the change made, the user who made it, the time, and the compliance impact. Your team addresses drift before it accumulates into findings during an examination.
Regulators do not just want to see that you are compliant today. They want to see that you are improving over time. Guardian's historical trend data shows Secure Score movement, gap closure rates, remediation timelines, and compliance coverage expansion.
This trend data is the strongest evidence you can present in an examination. It demonstrates that your institution treats compliance as an ongoing discipline, not a point-in-time exercise.
When Guardian identifies a compliance gap, the remediation is documented from start to finish. The gap is logged. The remediation steps are recorded. The completion date is captured. The post-remediation state is verified.
This audit trail shows examiners that your institution does not just find problems. It fixes them and documents the fix.
Week 1-2: Guardian baseline assessment identifies all compliance gaps across your tenant. Most institutions discover 20-40 gaps they did not know existed. These range from missing MFA enrollments to Conditional Access policies that allow legacy authentication.
Week 3-4: Hardening sprint closes the highest-risk gaps. Legacy authentication gets blocked. MFA enrollment is completed for all users. DLP policies are deployed for borrower data types. Each action is documented with regulatory mapping.
Month 2: Continuous monitoring begins catching drift events. The initial spike of findings decreases as the hardened baseline takes hold. Your team starts working from prioritized daily compliance reports.
Month 3: Steady state. Daily reports contain a handful of items. Historical trend data shows consistent improvement. Your next examination becomes a documentation exercise, not a panic project.
IBM's 2025 Cost of a Data Breach Report found that financial institutions paid $6.08 million per breach. Regulatory fines, borrower notification costs, credit monitoring, legal fees, and reputational damage compound quickly.
But the cost is not just the breach itself. Non-compliance penalties exist independently of breaches:
The cost of Guardian is a fraction of a single penalty. The cost of not having it is the penalty plus the breach plus the business disruption.
GLBA (Gramm-Leach-Bliley Act): Federal law requiring financial institutions to implement safeguards for customer data. The FTC Safeguards Rule provides the enforcement framework with specific requirements for risk assessments, access controls, encryption, and monitoring.
NIST Cybersecurity Framework 2.0: Updated federal framework adding governance as a sixth core function alongside Identify, Protect, Detect, Respond, and Recover. Now the primary reference for financial institution cybersecurity assessments.
FFIEC Cybersecurity Assessment Tool: The former standard self-assessment tool for financial institutions, retired August 2025. Institutions should now use NIST CSF 2.0 directly or NCUA's updated ACET for credit unions.
Conditional Access: Microsoft Entra ID policy engine that enforces access controls based on user identity, device compliance, location, and risk level. Maps to access control requirements across GLBA, NIST CSF, NYDFS, and NCUA frameworks.
Data Loss Prevention (DLP): Microsoft Purview feature that identifies, monitors, and protects sensitive data types such as Social Security numbers, bank account numbers, and borrower financial records. Required by GLBA and FTC Safeguards Rule.
Guardian runs nightly scans across your Microsoft 365 tenant and stores timestamped evidence of MFA enforcement, device compliance, Conditional Access configurations, and DLP policy status. This data maps to GLBA, FTC Safeguards Rule, NIST CSF 2.0, NYDFS, and NCUA frameworks simultaneously. Your team pulls one report that answers questions from five regulatory audiences.
The FFIEC retired its Cybersecurity Assessment Tool in August 2025 and directed financial institutions to NIST Cybersecurity Framework 2.0. The NCUA released an updated ACET aligned with the same framework for credit unions. Institutions still referencing the old FFIEC CAT in their documentation need to update their assessment methodology and compliance evidence to reflect NIST CSF 2.0.
The FTC Safeguards Rule requires non-bank financial institutions including mortgage lenders to designate a security coordinator, conduct risk assessments, implement access controls, encrypt customer data, deploy continuous monitoring, and maintain an incident response plan. Guardian's hardening and monitoring operations address each of these requirements through Microsoft 365 native controls.
Guardian scans your Microsoft 365 tenant nightly and compares current configuration against the documented baseline. When a Conditional Access policy is modified, an exclusion is added, or a device falls out of compliance, the drift event is logged with the change details, user responsible, timestamp, and compliance impact. Your team addresses drift within 24 hours instead of discovering it during an examination.
Yes. In 2025, cyber insurance carriers began factoring Microsoft Secure Score, MFA enforcement rates, and endpoint protection status into underwriting decisions. Demonstrating strong controls in MFA and Data Protection categories can reduce premiums. Guardian provides historical trend data and current posture documentation that CFOs use during insurance renewal negotiations.
Your next examination is coming. With Guardian, it is a reporting exercise, not a fire drill. The evidence exists. The trends are documented. The gaps are already being closed.
Talk to an ABT compliance specialist about building audit-ready security operations for your institution.