Hey Guru! I’m looking at an FIL that came out recently (FIL-19-2019), and trying to figure out how to react to it. In your opinion, how do we “ensure that business continuity and incident response risks are adequately addressed” in our contracts? We do get copies of their BCP/IRP plans and their insurance, and we […]
Hey Guru! Our institution works with a third-party that has recently engaged with a company in a foreign county to begin assisting them in taking care of our institution’s IT matters. Do we need to perform a review on this new foreign third-party? When evaluating this situation, the first step is to understand the parties […]
Hey Guru! I have heard a lot about GDPR recently, but I am not terribly familiar with it. I already break my back to stay in compliance with FFIEC guidance. Do I have anything more to worry about here? GDPR has certainly been in the news for the past few months as implementation was required […]
Hey Guru! We’re doing our due diligence on a new HR software package. We’ve requested the vendor’s financials and a SOC 2 report, but they told us they don’t provide financials (they are privately held), and their SOC 2 won’t be completed until the end of the year. They do have a SOC 1. What […]
Hey Guru! We just completed the Cybersecurity Assessment, so now we have our current risk and control maturity levels identified. Can we draw any conclusions about our average risk and control levels? For example, most of our risks are in the Least and Minimal areas, but we do have a few Moderate as well. Can we […]
Hey Guru! Management is asking why we have to complete the FFIEC Cybersecurity Assessment Tool when it is voluntary. They feel it is too much work if it is not mandatory. I think it is still needed even though it is voluntary. Is there any documentation as to why it is still necessary for OCC […]
Hey Guru I saw multiple references to the term “risk appetite” in the FFIEC Cybersecurity Assessment Tool. What exactly is risk appetite, and how can I address this in my institution? They just released Management Handbook contains 10 new references to “risk appetite”, including a requirement that the Board has defined the institution’s risk appetite and it’s risk tolerance levels. […]
Hey Guru Where in the handbook does it state the Bank should request exam reports on vendors from their regulatory body? Although there is no formal FFIEC written requirement for obtaining the service provider’s regulatory examination report (report of examination, or ROE), it is mentioned as a best practice in the FFIEC 2012 TSP Handbook: […]
Hey Guru Our examiner is asking about the “scope” of our IT audits. What is she referring to, and how do we define a reasonable scope? Audit results are one of the first things examiners want to see, and the “scope” of the audit is very important to examiners. In fact, the term is used […]
Hey GuruI recently had an FDIC examiner tell me that we needed to make a better distinction between a vendor and a service provider. His point seemed to be that by lumping them together in our vendor management program we were “over-analyzing” them. He suggested that we should be focused instead only on those few […]
