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FFIEC Issues 2 Statements on Cybersecurity
Both statements address recent cybersecurity threats; one targeting online credentials (passwords, usernames, e-mail addresses that may be used by employees or customers to authenticate themselves), and one addressing destructive malware. The statements advise specific risk mitigation steps institutions should consider, and I thought it would be instructive to compare the steps to see which are common to…
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Guru Briefs – OCC on Cybersecurity & MRA’s, FFIEC on Cybersecurity Assessments
(NOTE: Guru Briefs are short takes on recently released regulatory activity. They are not a detailed analysis, but designed to draw attention to the Guru’s initial impressions.) In this edition: The OCC has been particularly active on the regulatory front lately, and even non-OCC institutions may want to pay attention, as the head of the OCC…
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Cybersecurity – Part 2
In Part 1 I discussed the increasing regulatory focus on cybersecurity, and what to expect in the short term. In this post I want to dissect the individual elements of cybersecurity, and list what you’ll need to do to demonstrate compliance on each one going forward. So here are the required elements of a cybersecurity program, followed…
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Cybersecurity – Part 1
Cybersecurity has gotten a lot of attention from regulators lately, and with assessments already underway it promises to be a regulatory focus for the foreseeable future. But exactly what are they expecting from you, and how does that differ from what you may be doing already? More importantly, how should you demonstrate that you are…
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Is It Time to Take the CAT to the Vet?
How a New Framework Can Improve Cybersecurity Assessments in Financial Institutions. In the age of digital banking, maintaining robust cybersecurity risk assessments and control reviews is paramount to protecting sensitive data from potential threats, and passing rigorous IT audits and examinations. Historically, a key tool in the arsenal has been the Cybersecurity Assessment Tool (CAT)…
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The State of the (Credit) Union According to the NCUA Chairman
Last month, NCUA chairman Todd M. Harper delivered his “State of the (Credit) Union” during the 2023 Governmental Affairs Conference. Harper covered multiple areas of interest to credit unions including: But in this post, we’ll focus on 3 topics directly related to information security: cybersecurity risk, the need for centralized vendor authority, and Fintechs. The…