1. Compliance is Pretty Important, I Guess Florida Gulf Coast ARMA Meeting

2. Introduction and Disclaimer I’m Me I’m Not Your Attorney (at least not yet…)

3. Overview Perspective on Compliance Financial Compliance Elements Areas of Concern Recommendations Q & A

4. Perspective on Compliance Perfect Compliance Reasonable Standard of Professional Care

5. Financial Compliance Elements Client/Record Types  Student Records  Bank Records  Auto Loans  Corporate  Explanation of Benefits  Credit Reports  Credit Card Information Laws/Standards  Family Educational Rights and Privacy Act (FERPA)  Gramm-Leach-Bliley (GLBA)  Sarbanes-Oxley (SOX)  HIPAA  Fair and Accurate Credit Transactions Act (FACTA)  Fair Credit Reporting Act (FCRA)  Payment Card Industry Data Security Standard (PCI)

6. Areas of Concern Access/Transmission  Privacy and Security vs Accessibility Maintenance  Hard Copies  Digital Copies  Data

7. Recommendations Know Your Clients Know Yourself Know Your Vendors (Kn)Adjust As Needed

8. Recommendations Know Your Clients

9. Recommendations Know Yourself  Risk Assessments  Product Specific Issues  Third Party Audits  Controls

10. Recommendations Know Your Vendors  Subcontractor Agreements  Digital Records Vendors  Software/IT Solutions

11. Recommendations (Kn)Adjust As Needed Business Associate Agreements Vendor Agreements Internal Policies and Procedures Training

12. Any Questions?

13. Mark Hinely Regulatory Compliance Specialist KirkpatrickPrice m.hinely@kirkpatrickprice.com 850.339.5963 m.hinely@kirkpatrickprice.com