Tag: Examination

  • “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…

  • FDIC changing annual IT report to Board?

    Based on recent examination findings, it would appear that the FDIC is changing what they expect to see in the annual information security report to the Board of Directors.  The requirement for the report is established in the FFIEC Information Security Handbook where it states that a written report to the board should describe the…

  • 2012 Compliance Trends, Part 5 – Uncertainty (UPDATE)

    Similar to my previous post on Risk Assessments, I believe Uncertainty is also a 2-part trend: – Uncertainty about future regulatory changes, and – Uncertainty about the interpretation of existing regulations

  • Access Rights a frequent finding

    In reviewing recent audit and examination findings, the issue of access rights and permissions is coming up with increasing regularity.  Making sure that end-users have no more access rights than absolutely necessary to do their job is one of the best information security controls.  According to the FFIEC, formal access rights administration for users consists…

  • Material Loss Reviews: Does responsibility = liability?

    I asked in my previous post whether or not the regulators should share any of the blame when institutions fail, and if so, should they shoulder any of the liability?  The thought occurred to me as I was reviewing some recent Material Loss Reviews. A Material Loss Review (MLR)  is a post-mortum written by the…

  • Exam preparation – less equals more?

    One of the more surprising findings from my recent examination experience survey (thanks again to all that participated!) is that there doesn’t seem to be a direct relationship between the amount of time spent preparing, and examination results. I’ll elaborate in a moment, but first, here are the final survey demographics: There were 80 total…