ILLUSTRATIVE INPUT. FICTIONAL MATTER. NOT CLIENT ADVICE.

Alder Tax Services LLC is a fictional nonbank business preparing personal income-tax returns for individuals. For this demonstration, assume it is within the FTC’s enforcement jurisdiction rather than another financial regulator’s. It maintains records for approximately 4,200 current individual customers. Its archive contains former-customer files whose distinct consumer count has not been reconciled. No personal records or identifiers are supplied.

The business asks whether having fewer than 5,000 current customers means that the FTC Safeguards Rule does not apply. It wants to understand the significance of retained archives and which obligations would remain even if the rule’s small-institution exception were available.

Prepare a preliminary U.S. federal scoping memorandum as of 25 September 2026, using the identified primary sources. Separate supplied facts, assumptions, authority, analysis and missing information. Explain the limits of the question. Do not provide a complete security compliance assessment, state-law analysis, tax-law analysis or advice about a real incident. No breach has been alleged.

Use the current text of 16 CFR Part 314 and the FTC business guidance identified in the source list. Identify any source you could not access. Do not claim that an active-customer count establishes the total number of consumers about whom information is maintained. Do not make external filings or representations.