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 […]
The statement is here, and is intended to provide additional awareness about the possible use of cyber insurance to off-set financial losses resulting from cyber incidents. Here are a few high-level observations: First of all, we’ve seen several announcements from various organizations stating that “the FFIEC has released new guidance…”. The statement makes it clear […]
The FFIEC Cybersecurity Assessment Tool has been out since 2015, and by now almost all financial institutions have completed it at least once, some as many as 3-4 times. Although most of the examiner feedback we’ve gotten indicates that simply completing is all regulators are looking for at this time, the FFIEC made it clear […]
The FFIEC recently released a long-awaited update to the Cybersecurity Assessment Tool, and we think overall it is a relatively minor but useful evolution. But before we get into the details of what the update does address, it’s important to note that it did not address the ambiguity issues that plague the current assessment. One […]
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 […]
In the first update in over 10 years, the FFIEC just completely rewrote the definitive guidance on their expectations for managing information systems in financial institutions. This was widely expected, as the IT world has changed considerably since 2006. There is much to unpack in this new handbook, starting with what appears to be a […]
Starting immediately, all FDIC-examined institutions will be subjected to new IT examination procedures, the first major overhaul since December 2007. The new format is dubbed the InTREx program (Information Technology Risk Examination), and is designed to be a bit simpler in the pre-examination phase. In fact, the InTREx has only 26 questions vs. 59 for the 12/07 […]
Hey Chuck, A bank I used to work for had a bad scare recently – they got hit with ransomware!! Best they can tell, an email attachment was the culprit. That bank is very similar to my current bank, and I thought they had a solid Information Security program while I was there. As the […]
