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FFIEC Cybersecurity Assessment Tool Update
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…
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Vendor Management in 3 Parts. Part 3 – Risk Management (or, “can we or can’t we?”)
The last step in the vendor management process is to manage, or control, the risk that was identified in step 1, and assessed (as inherent risk) in step 2. Controlling risk is defined as applying risk mitigation techniques (or “controls”) to reduce risk to acceptable levels It’s important to understand that risk can never be completely eliminated,…
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A Look Back at 2013…and a Look Ahead – Part 1 (charts edition)
One thing that’s clear from the examination feedback I’ve received from financial institutions in 2013 is that examiners are spending less time in their safety & soundness examinations on the CAMELS “C”, “A”, & “L” (capital, asset quality and liquidity) issues, and more time on the “M” & “E” (management and earnings) issues. (There was…
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Ask the Guru: The IT Audit “Scope”
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…
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Incident Response in an Outsourced World
UPDATE – On June 6th the FFIEC formed the Cybersecurity and Critical Infrastructure Working Group, designed to enhance communications between and among the FFIEC members agencies as well as other key financial industry committees and councils. The goal of this group will undoubtedly be to increase the defense and resiliency of financial institutions to cyber…
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FDIC Supervisory Letter Issued on Critical Service Provider
(NOTE: Although the vendor in question has been publicized by the NCUA, I will not name it here because it is not relevant. If you currently contract with the vendor you know who it is, and you need to know how to respond to the letter. If you don’t, you’ll need to know how to…