Can you name the three cyber risks most likely to disrupt your firm — without having to think about it?
12 questions every smaller accounting firm should be able to answer — whether the FTC requires the paperwork or not.
The exemption reduces specific documentation requirements. It does not reduce the impact of an incident.

Answer Yes or No. Score what is genuinely in place today — not what you intend to do. The harder a question is to answer confidently, the more useful it is to investigate.
Can you name the three cyber risks most likely to disrupt your firm — without having to think about it?
Is MFA enforced on every system where client data is accessed — with no exceptions?
If ransomware hit, would every member of staff know what to do?
Could you hand a client or insurer documented evidence of your security measures today?
12 questions, Yes or No. Your score tells you where to focus first.
The small-firm exemption applies to specified Safeguards Rule provisions — but these four disciplines still answer the questions that matter during an incident, insurance renewal or client security review.
Know your risk
Identify your most sensitive information, where it lives, who can access it, and the controls you rely on — short enough to use, specific enough to drive action.
Test what you rely on
Scan for vulnerabilities, verify MFA is enforced everywhere it should be, run a backup recovery test, and re-check controls after any material change.
Decide before the crisis
An incident is a terrible time to decide who is in charge. A concise plan makes containment, escalation, communications and recovery easier under pressure.
Make it visible to leadership
Leadership should periodically review whether the security program still matches the business, its technology, its suppliers and the threats it faces.
That is the real question — not "are we required to have this?". A ransomware attack, compromised mailbox or stolen client file does not behave differently because your firm sits below a regulatory threshold.
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You will receive a written report showing where your firm stands, the key gaps we identify and what to fix first — a clear, prioritised view of your next steps.