Hey Guru! We’re doing our due diligence on a new HR software package. We’ve requested the vendor’s financials and a SOC 2 report, but they told us they don’t provide financials (they are privately held), and their SOC 2 won’t be completed until the end of the year. They do have a SOC 1. What […]
The last step in the vendor management process is to manage, or control, the risk that was identified in step 1, and assessed (as inherent risk) in step 2. Controlling risk is defined as applying risk mitigation techniques (or “controls”) to reduce risk to acceptable levels It’s important to understand that risk can never be completely eliminated, […]
What do all of the 2012 changes to the IT Examination Handbooks have in common? They are all, directly or indirectly, related to vendor management. I had previously identified vendor management as a leading candidate for increased regulatory scrutiny in 2012, and boy was it. (Not all of my 2012 predictions fared as well, I’ll […]
Although I have written about these relatively new reports frequently, and for some time now, it still remains a topic of great interest to financial institutions. Fully 20% of all searches on this site over the past 6 months include the terms “SOC” or “SOC 2”, or “SAS 70”. Some of this increased interest comes […]
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 […]
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 […]
In my first post in this series I discussed training (employee and customer) as a good candidate for increased regulatory scrutiny in 2012. Although these posts are in no particular order, I had initially intended to list “Management” as the next trend. However a comment made to me by a banker at a recent conference […]
The SOC 2 and SOC 3 audit guides have recently been released by the AICPA, and the SAS 70 phase-out becomes effective tomorrow. The more I learn about these new reports the more I like them. First of all, as a service provider to financial institutions we will have to prepare for this engagement (just […]
I’ve written about the replacement for the SAS 70, which officially phases out on June 15th, previously. But because this one report is being replaced with 3 new reports, financial institutions have an additional challenge that they didn’t have before. Your vendor management program must now determine the most appropriate report to request based on […]
With the SAS 70 phasing out on 6/15, financial institutions have a dual challenge; determining the best report to request, and evaluating the report they are provided. To assist with this challenge, I’ve created two documents. The first, or Step 1, is a SOC Selection Flowchart, which is available here. This will assist in determining […]
