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FDIC Institutions still getting UIGEA (Reg GG) findings – UPDATE
Update 1 – 12/5/2011 to add examination procedures*. Update 2 – 2/13/2012 to emphasize policy requirements. Update 3 – 10/8/2012 to add specific courses of action Read the rest of the article
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“Operational Risk Increasing”
In a recent speech to the Exchequer Club1, Thomas J. Curry, the new head of the OCC, stated that although asset quality has improved, charge-off rates have fallen, and capital now stands at its highest level in a decade, another type of risk is gaining increasing prominence; Operational Risk. “Some of our most seasoned supervisors,…
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Patch deployment – now or later? (with interactive poll!)
We recently saw an examination finding that recommended that “Critical Patches be deployed within 24 hours of notice (of patch release)”. This would seem to contradict the FFIEC guidance in the Information Security Handbook that states that the institution: “Apply the patch to an isolated test system and verify that the patch… (1) is compatible…
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5 “random” facts
Fact 1 – According to the U.S. Bureau of Labor Statistics, the increasing complexity of financial regulations will spur employment growth of financial examiners. In fact it is expected to experience the third largest growth of all career paths through 2018: Fact 2 – According to Rep. Shelly Moore Capito (R-W.Va.), author of H.R. 3461,…
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CFPB Examinations Are Coming – UPDATE 2
Coming soon to your financial institution: Dear Board of Directors: Pursuant to the authority of the Dodd-Frank Wall Street Reform… Read the rest of the article
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“Data-flow diagrams”
This request was seen in a recent State examiners pre-examination questionnaire, and although I usually like to see a request a couple of times from different examiners before identifying it as a legitimate trend, this one could prove so potentially problematic that I thought I needed to get ahead of it. Before we go much…
