On June 23, 2020, the FDIC posted “The Interagency Examiner Guidance for Assessing Safety and Soundness Considering the Effect of the COVID-19 Pandemic on Institutions.” FIL-64-2020 This statement this is only one of several interagency statements issued since the start of the Covid-19 Pandemic outlining supervisory principles examiners will use to guide their safety and […]
The FFIEC Cybersecurity Assessment Tool has been out since 2015, and by now almost all financial institutions have completed it at least once, some as many as 3-4 times. Although most of the examiner feedback we’ve gotten indicates that simply completing is all regulators are looking for at this time, the FFIEC made it clear […]
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 […]
Hey Guru! We just completed the Cybersecurity Assessment, so now we have our current risk and control maturity levels identified. Can we draw any conclusions about our average risk and control levels? For example, most of our risks are in the Least and Minimal areas, but we do have a few Moderate as well. Can we […]
In the first update in over 10 years, the FFIEC just completely rewrote the definitive guidance on their expectations for managing information systems in financial institutions. This was widely expected, as the IT world has changed considerably since 2006. There is much to unpack in this new handbook, starting with what appears to be a […]
This latest update to the IT Examination Handbook series comes 11 years after the original version. And although IT has changed significantly in the past 11 years, the requirement that financial institutions properly manage the risks of IT has not changed. This new Handbook contains many changes that will introduce new requirements and new expectations […]
UPDATE: Safe Systems just released their Enhanced CyberSecurity Assessment Toolkit (ECAT) – This enhanced version of the FFIEC toolkit addresses the biggest drawback of the tool; the ability to collect, summarize, and report your risk and control maturity levels. Once risks and controls have been assessed (Step 1 below), institutions will now be better able […]
This caught me by surprise as it was not formally announced in the “What’s New” section, but the Appendix J update to the Business Continuity Planning Handbook apparently constituted a complete update to the Handbook. Here is what the press release said in part: The Federal Financial Institutions Examination Council (FFIEC) members today issued a revised […]
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 […]
The FFIEC just issued new BCP Guidance in the form of a 16 page addendum to the existing 2008 IT Handbook on Business Continuity Planning. It is titled “Appendix J: Strengthening the Resilience of Outsourced Technology Services”, and it has significant implications for both financial institutions and service providers, and across the entire business relationship […]
In Part 1 I said that vendor management, just as any other risk management endeavor, consists of 3 basic phases; Identify the risk Assess the risk, and Control the risk I also discussed why risk identification was a more difficult task today because of the “access to data” question, and also because “data” includes not just NPI, but confidential […]
