Regulatory Reality:

assessment


March 6, 2013  5:19 PM

Security Standards: What’s in a name?



Posted by: David Schneier
assess, assessment, assessments, Audit, auditor, audits, CISO, community bank, control, controls, credit union, credit unions, data security, framework, information security, information security office, infrastructure, ISO, risk assess, risk assessment, risk assessments, risk management, risk-based

I had an interesting phone call recently with someone in a CISO-type position.  They were looking for a consultant to help them keep a seat warm working with information security risk assessments and were hoping to find a resource with practical experience using the NIST 800-53 standard.  It was...

October 22, 2012  2:09 PM

Are banks unfairly scrutinized?



Posted by: David Schneier
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A few years back when I first cut over to working somewhat exclusively with financial institutions I memorized an elevator speech that still somewhat defines who I am and what I do professionally.  Part of the speech pointed out that my firm helped "banks and credit unions meet regulatory...


September 21, 2012  3:44 PM

Are self-assessments the right way to go?



Posted by: David Schneier
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About a decade ago a family member chastised me for having an auto repair shop do my oil changes for me.  She (yeah, you’re reading that right – “she”) pointed out how ridiculously easy it was to drain the old oil, replace it with the new stuff and check a wide variety of fluid levels,...


July 21, 2012  8:25 PM

CFPB: Filling the regulatory void left by Sheila Bair



Posted by: David Schneier
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I was an unabashed fan of Sheila Bair and made no secret of that fact.  She was a breath of fresh air in a line of work where everything is stale and always at least a little boring.  Not that Martin Gruenberg is any less effective running the FDIC, he's just a whole lot less interesting to pay...


July 6, 2012  3:18 AM

Risk: The core issue behind regulatory requirements



Posted by: David Schneier
assess, assessment, assessments, Audit, audits, bank, banking, banks, compliance, compliant, control, credit union, credit unions, CU, enterprise risk, enterprise risk management, ERM, exam, examination, examinations, examiner, exams, FDIC, Federal Reserve Bank, FFIEC, financial institutions, framework, FRB, general controls, GLBA, governance, GRC, guidance, information security, information security office, infrastructure, NCUA, PII, policy, procedure, regulation, regulations, regulations audit, risk assessment, risk assessments, Risk IT, risk management, risk rating, risk-based, risks, threats, vendor, Vendor Management, vendor risk, vendor risk assessment

There's a joke of sorts within my personal circle of family and friends regarding what it is that I do these days.  Ask me and I'll tell you that I'm a regulatory compliance expert who advises financial institutions on how to comply with the myriad rules and regulations governing information...


April 29, 2012  7:43 PM

Internal Audit: Whose side are they on anyway?



Posted by: David Schneier
assessment, assessments, Audit, compliance, control, control owners, controls, findings, GLBA, internal audit, NCUA, regulations, regulatory, Regulatory Compliance, risk, risk assessments, risks

My first encounter with an auditor was back in the mid-90's while working as an application project manager for a Fortune 100 company.  The group responsible for change management was going through an audit of their process and one of the changes that was selected for review happened to belong to...


March 23, 2012  3:24 PM

GRC presents a broad spectrum; is it too broad?



Posted by: David Schneier
assessment, Audit, compliance, GRC, HIPAA, PCI, regulations, regulatory, Regulatory Compliance, risk, risk assessment, SOX

In early 2004 I co-authored my first Sarbanes-Oxley (SOX) controls framework for a client.  Just about the entire thing required manual testing that, if everything worked as planned would require a full-time resource to support.  About thirty seconds after submitting the framework draft to the...


January 8, 2012  9:27 PM

Maintaining compliance is often the Missing Link.



Posted by: David Schneier
assess, assessment, Audit, compliance, exam, examination, examiner, FDIC, GLBA, NCUA, regulations, regulatory, Regulatory Compliance, risk, risk assess, risk assessment

I've been in the solutions selling business on and off for about a decade but exclusively so over these past four years.  Up until becoming a partner in my current practice I pretty much was always only involved in helping sell the solution and usually implementing it before moving on.  Seldom...


December 22, 2011  9:44 PM

Why I don’t trust hosted or SaaS solutions.



Posted by: David Schneier
assessment, Audit, compliance, GLBA, NPPI, PCI, PII, regulatory, Regulatory Compliance, risk, risk assessment

Let me begin by sharing a story from the way back files.   In the mid 80’s when I was first starting out in my career I was working as a junior programmer in Manhattan.  Courtesy of playing on the corporate softball team I became acquainted with a fairly diverse group of...


November 18, 2011  12:22 PM

Why vendor management is a big GLBA deal.



Posted by: David Schneier
assessment, Audit, compliance, FDIC, Federal Reserve Bank, FRB, GLBA, NCUA, OCC, OTC, regulations, regulatory, Regulatory Compliance, risk, risk assessment, vendor, Vendor Management, vendor risk, vendor risk rating

I don't think I'm due to post about vendor management again at least until January 2012 (I try to limit topics to twice a year) but I've had something kicking around my head for a few days now and it needs a proper vetting. Does anyone know why vendor management is such a big issue for banking...