Non-bank financial institutions are squarely in scope, and the Safeguards Rule is specific about testing.
If you're a mortgage broker, fintech, auto dealer offering financing, or another non-bank financial institution, the GLBA Safeguards Rule applies to you — and its testing requirement is more explicit than most: annual penetration testing plus twice-yearly vulnerability scanning for institutions without continuous monitoring. This page gets the penetration-testing half moving without a drawn-out sales process.