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 […]
Hey Guru Our examiner is asking about the “scope” of our IT audits. What is she referring to, and how do we define a reasonable scope? Audit results are one of the first things examiners want to see, and the “scope” of the audit is very important to examiners. In fact, the term is used […]
We recently saw an examination finding that recommended that “Critical Patches be deployed within 24 hours of notice (of patch release)”. This would seem to contradict the FFIEC guidance in the Information Security Handbook that states that the institution: “Apply the patch to an isolated test system and verify that the patch… (1) is compatible […]
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 […]
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 […]
Although not specific to the financial industry, the new guidelines provide a comprehensive overview of the privacy and security challenges of this increasingly popular computing model. It’s worth a look by both financial institutions considering cloud-based services, as well as service providers, because NIST guidelines often wind up as the basis for new or updated […]
One of the most common examination findings recently (particularly with the FDIC) has been the lack of an IT Strategic Plan. I’m not sure why the focus lately (perhaps the shift from the CAMELS “A” to the “M”?), but the concept is certainly not new. The regulatory mandate for it is found in the 2004 […]
If there was a process that was mentioned 43 times in 7 of the 12 FFIEC IT Examination Handbooks, (including 12 times in the Information Security Handbook alone!), would you consider implementing it? How about if it virtually assured better audits and examinations? OK, you’re interested, but the last thing you need is to implement […]
When you were a kid, you hated the “pop quiz” right? But if the teacher allowed you to use your notes and textbooks, you felt like you at least had a fighting chance. I’ve taken both proctored and “open book” certification exams, and I’ve always felt that open-book exams more accurately reflected how most of […]
