One of several changes implemented in the 2019 FFIEC BCM Examination Handbook is a subtle but important differentiation between a BCMP “test” and an “exercise”. I discussed some of the more material changes here, but we’re starting to see examiner scrutiny into not just if, but exactly what and how you’re testing. According to the […]
Hey Guru! Are the Gramm–Leach–Bliley Act (GLBA) and the General Data Protection Regulation (GDPR) similar enough to apply the same or equivalent set of layered controls? My understanding is that GDPR has placed a higher premium on the protection of a narrower definition of data. So, my question is more about whether FFIEC requirements for […]
In the past year to year and a half, nearly all of the IT examination findings I’ve seen have in the broad category of “documentation”, or more specifically, lack thereof. In other words, policies and procedures were satisfactory, but documentation was either non-existent, or insufficient, to demonstrate that actual practices followed policy and procedure. To […]
