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 […]
Originally released in 2001, the FDIC recently re-issued 3 publications related to managing outsourced relationships: Effective Practices for Selecting a Service Provider Tools to Manage Technology Providers’ Performance Risk: Service Level Agreements Techniques for Managing Multiple Service Providers What struck me about this re-release, and the fact that they were released without modification of any […]
Hey GuruI recently had an FDIC examiner tell me that we needed to make a better distinction between a vendor and a service provider. His point seemed to be that by lumping them together in our vendor management program we were “over-analyzing” them. He suggested that we should be focused instead only on those few […]
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 […]
Further to the previous post, the memorandum requires the FDIC opinion to prevail in the event that an institutions’ PFR (primary federal regulator) CAMELS rating differs from the FDIC: If the FDIC’s CAMELS ratings for an institution differ from a PFR’s assigned ratings, the FDIC is required to provide the PFR with an explanation of […]
According to a memorandum of understanding just signed by all the primary federal regulators (FDIC, OTS, OCC and Fed), the FDIC now has the authority to step in whenever they feel the DIF (deposit insurance fund) is in jeopardy. Although this is primarily targeted at larger (>$10b) institutions, it also applies to smaller (<$10b) institutions as well, and applies to ANY threat to the DIF, not just under-capitalization (i.e. any safety and soundness concerns)…
