Raven Compliance FTC SAFEGUARDS RULE · 16 CFR PART 314
For US tax and accounting firms

Your written security plan was finished before your firm started using AI.

The Safeguards Rule requires tax preparation firms to keep a written information security program. Most firms built theirs from the IRS template. That template has not been revised since August 2024, so it says nothing about AI tools, which is now one of the main ways client data leaves the office. We wrote the part that is missing, and the rest of the plan around it.

The template most firms used Rev. 8-2024 IRS Publication 5708. 29 pages, fill-in-the-blanks. Zero mentions of AI, large language models, or third-party model providers.
What your office does now 2026 Staff summarising client correspondence, drafting memos, cleaning up spreadsheets, researching positions. Often in tools nobody formally approved.
That gap is the finding. Your written program does not describe what actually happens in your office, and a written program that does not match practice is the problem the rule exists to prevent.

What the rule actually requires

Not our interpretation. The FTC's own guidance for businesses, which names tax preparation firms as covered financial institutions. ftc.gov

16 CFR 314.4 · REQUIRED ELEMENTS

A covered firm must develop, implement and maintain a written information security program. Among the elements the rule names:

  • Designate a Qualified Individual to oversee the program
  • Conduct a written risk assessment
  • Implement access controls, encryption, multi-factor authentication and secure disposal
  • Oversee service providers handling customer information
  • Establish a written incident response plan
  • Report in writing to governance at least annually

Three of those six are documents that must physically exist. If someone asked your firm for its written risk assessment this afternoon, could you produce it?

What is in the pack

Nine documents, about 12,600 words. Editable Word files and PDFs. Instant download.

No.DocumentWhat it does
00Start HereWhat to work through, in what order, and what you must customise
01WISP CoreThe written plan itself, structured to the elements above
02AI Use PolicyApproved and prohibited tools, an absolute bar on client data in consumer AI tools, vendor review criteria, training opt-out requirements, human review obligations, staff attestation
03Risk Assessment WorkbookThe written risk assessment, with worked examples
04Incident Response PlanDetection through recovery, including IRS Stakeholder Liaison breach reporting and an incident log
05Qualified Individual DesignationThe designation letter and the duties that come with it
06Staff Training AcknowledgementOne page, signed, covering security basics and the AI policy
07Implementation ChecklistDownloaded to documented, with honest time estimates per step
08AI Tool Approval Request FormWhat a staff member fills in before using a new AI tool, routed to the Qualified Individual

Take document 08 free. No email required.

The AI Tool Approval Request Form is one page and useful entirely on its own. If your firm adopts nothing else from us, adopt this: it is the difference between an AI policy that gets read once and one that actually governs what staff do. Look at the quality, then decide about the rest.

Send me the form

Two things we will tell you that others will not

The IRS template is free, and for some firms it is enough.

If nobody at your firm has used an AI tool on anything touching client information, IRS Publication 5708 is a reasonable starting point and you should keep your money. We are not going to pretend otherwise to make a sale.

There is also a well-made WISP pack on the market at around $59. If a WISP is genuinely all you need, buy that one. We are four times that price for exactly one reason: the two AI documents, which as far as we can find nobody else sells at any price. That is the whole argument, and if it does not apply to your firm then neither do we.

Pricing

The Pack $249
  • All nine documents
  • Editable Word plus PDF
  • Instant download
  • Free updates for 12 months
  • 30-day refund, no questions
Pack and Walkthrough $449
  • Everything in the pack
  • A 45-minute implementation call
  • We work through the checklist with you
  • Your questions answered against your actual setup

Limited to three of these a week, because the calls are done by a person and we would rather say no than run late.

Firms with three or more offices: $599 for a multi-office licence. Same documents, broader use rights.

Close the gap this month

November to January is when firms do compliance housekeeping. Doing it now beats doing it in filing season, which is the only honest piece of urgency here.

Get the pack — $249

30-day refund, no questions and no form.
One firm, one licence, yours to adapt however you need.

Questions

Does buying this make us compliant?

No, and anyone telling you a document pack does is selling you something. Compliance means having the written program, actually following it, and keeping evidence that you did.

This gives you the written program and a checklist for following it. The following is yours. We would rather say that plainly up front than have you discover it later.

Could our IT person or accountant write this?

Yes. It is roughly eight hours of their time at their rate, plus the reading to know what the rule requires. That is the entire value proposition and we are comfortable saying so. If eight of their hours cost less than $249, write it yourself.

Is this legal advice?

No. These are templates for your firm to adapt to its own circumstances, and that disclaimer appears in all nine documents, not just in the footer. We are not a law firm and we are not your counsel. If your situation is unusual, have a lawyer read it.

Who wrote it?

A small independent team. Every document is original prose written against the published rule text, not copied from the IRS template or from any vendor.

We are new and we have no client list to show you. That is exactly why document 08 is free with no email required: look at the actual work and judge from that rather than from anything we claim about ourselves.

What if it is not useful?

30 days, full refund, no questions and no form to fill in. Email and we send the money back.