Currently, financial institutions are required to report a cyber event to their primary federal regulator under very specific circumstances. This requirement dates back to GLBA, Appendix B to Part 364 and states that FI incident response plans (IRP’s) should contain procedures for: “Notifying its primary Federal regulator as soon as possible when the institution becomes […]
Back in June of this year the FFIEC released an update to the 2004 Operations Handbook called Architecture, Infrastructure, and Operations (AIO). As the lengthier name implies, this was not simply an update, it also greatly expanded the scope of operations to include architecture and infrastructure principles and practices. This reflects the tight integration between […]
In response to an expanded cybersecurity threat landscape, the FFIEC just issued an update to agency expectations for access and authentication to financial institution products and systems. This update replaces both the 2005 and the 2011 authentication guidance, and has been extended beyond digital banking (ebanking) customers to include everyone and everything that might have […]
Update: Since publishing this post, these rules have been finalized. We have a new post covering those details here. We first wrote about incident notification over ten years ago, and based on feedback from our cyber testing experience, financial institutions are still struggling with the issue of whether or not to notify their customers and […]
From SafeSystems.com/Safe-Systems-Blog Safe Systems recently published a two-part regulatory compliance blog series that looked back at 2020 and ahead to 2021. In Part 1, we explored how regulations related to the Pandemic dominated the compliance landscape early in 2020 forcing financial institutions to make adjustments to their procedures and practices on the fly. In Part […]
Both the State banking regulators and the Treasury Department have issued recent advisories to financial institutions regarding the ransomware threat. Ransomware is defined as a form of malicious software (“malware”) designed to block access to a computer system or data, often by encrypting data or programs, in order to extort ransom payments from victims in […]
One of several changes implemented in the 2019 FFIEC BCM Examination Handbook is a subtle but important differentiation between a BCMP “test” and an “exercise”. I discussed some of the more material changes here, but we’re starting to see examiner scrutiny into not just if, but exactly what and how you’re testing. According to the […]
Hey Guru! Are the Gramm–Leach–Bliley Act (GLBA) and the General Data Protection Regulation (GDPR) similar enough to apply the same or equivalent set of layered controls? My understanding is that GDPR has placed a higher premium on the protection of a narrower definition of data. So, my question is more about whether FFIEC requirements for […]
On June 23, 2020, the FDIC posted “The Interagency Examiner Guidance for Assessing Safety and Soundness Considering the Effect of the COVID-19 Pandemic on Institutions.” FIL-64-2020 This statement this is only one of several interagency statements issued since the start of the Covid-19 Pandemic outlining supervisory principles examiners will use to guide their safety and […]
March 30, 2020 – Federal Reserve Statement on Supervisory Activities Where did it come from, and where can I find it? The Federal Reserve Who needs to know about it? All financial institutions supervised by the Federal Reserve Why was it Issued? To address adjustments in their supervisory approach in light of COVID-19 What does […]
Hey Guru! Are we required to post any kind of statement to the public or our customers as to our readiness for the COVID-19? If so, can you direct me to the kinds of things we need to say? We are working on an ad to educate our customers on how to use our online […]
