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 […]
Background Similar to the Joint Statement on Destructive Malware issued in January in response to heightened geopolitical cyber risks from foreign actors, the FFIEC just released an Interagency Statement on Pandemic Planning in response to the current COVID-19 epidemic. Similar to the Destructive Malware statement, this statement does not impose any additional regulatory expectations on […]
The all new IT Examination Handbook is more than an update, it’s a complete re-write, and represents a significant change in how the business continuity process is managed. It also has several new expectations regulators will be looking for from financial institutions1. In fact, that is one of the most interesting changes; the term “institution” […]
Hey Guru! In my last IT examination, one of the findings was that the scope and cycle of our IT audits should be more closely tied to risk. We have IT audits every 12 months, what else should we be doing? By conducting Information Technology audits every 12 months, you’ve effectively (and correctly) determined that […]
A Standardized Approach On August 28th, the FFIEC issued a press release entitled “FFIEC Encourages Standardized Approach to Assessing Cybersecurity Preparedness”. The release “…emphasized the benefits of using a standardized approach to assess and improve cybersecurity preparedness.” On the surface the this seems very logical and straightforward, but in fact this may have provided more […]
Hey Guru! We finished a FDIC exam earlier this year, and in the IT portion they hit us on our pandemic plan saying it “needed improvement.” Here is the actual finding: Management should improve the pandemic plan within the Business Continuity Plan. The pandemic plan has no defined action plan, nor has it been tested. […]
