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Commercially UNreasonable Security
So an appellate court has just reversed the PATCO court ruling, essentially deciding against the financial institution. They ruled that the banks’ security procedures were commercially UN-reasonable.
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FFIEC issues Cloud Computing Guidance
Actually the document is classified as “for informational purposes only”, which is to say that it is not a change or update to any specific Handbook and presumably does not carry the weight of regulatory guidance. However, it is worth a read by all financial institutions outsourcing services because it provides reinforcement for, and references…
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“Operational Risk Increasing”
In a recent speech to the Exchequer Club1, Thomas J. Curry, the new head of the OCC, stated that although asset quality has improved, charge-off rates have fallen, and capital now stands at its highest level in a decade, another type of risk is gaining increasing prominence; Operational Risk. “Some of our most seasoned supervisors,…
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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…
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FFIEC Handbook Update – Outsourcing
The FFIEC has just added a section to the Outsourcing Technology Services IT Examination Handbook, and it should be required reading for financial institutions as well as any managed service providers. The new section is Appendix D: Managed Security Service Providers, and it is the first significant change to the Handbook since it was released in…
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FFIEC Handbook Update – SAS 70 Transition
The FFIEC has just updated their online IT Examination InfoBase to address the AICPA phase-out of the SAS 70 reporting format. All references to “SAS 70” have now been replaced, and the SAS 70 sections of the Audit and Information Security Handbooks have been completely removed. Previously there were a total of 31 references to…
