Regulatory Reality:

Audit


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...


December 5, 2011  11:54 PM

The trouble with GRC.



Posted by: David Schneier
assessments, Audit, compliance, governance, GRC, regulations, regulatory, Regulatory Compliance, regulatory guidance, risk, risk assessments

I love GRC, at least the concept.  I've gotten way more than my fair share of print time expounding on its many virtues and how it continues to make inroads into so many organizations.  It's the next and necessary step in the evolution of audit and compliance, a fact (yes, fact) of which I'm...


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...


November 11, 2011  7:41 PM

Vishing, Smishing and Phishing: No end in sight.



Posted by: David Schneier
assessment, Audit, compliance, GLBA, hack, hacker, NCUA, phish, phishing, red flags, red flags identity theft, regulatory, Regulatory Compliance, scam, smish, smishing, vish, vishing

This is something akin to my annual public service announcement (PSA) for anyone who has cash-on-hand, a bank account, an investment account or perhaps even a piggy bank:  As long as you have money there's someone out there right now scheming to try and take it away from you. I'm having that...


September 14, 2011  6:27 AM

A new twist on regulatory guidance.



Posted by: David Schneier
assessment, Audit, bcp, business, business continuity, business continuity planning, compliance, disaster recovery, DR, GLBA, NCUA, regulation, regulatory, Regulatory Compliance, risk, risk assessment, vendor, Vendor Management

One of the oddity's of my career is how some issues present themselves in a wide range of my clients despite the fact that there's often no meaningful way to compare them in size.  Some have a single compliance person who is part Compliance Officer and part Information Security Officer and some...


August 28, 2011  3:17 PM

Will Hurricane Irene reveal your BCP’s strengths or weaknesses?



Posted by: David Schneier
Audit, auditor, bcp, business continuity, business continuity plan, compliance, disaster, disaster recovery, DR, exam, examiner, GLBA, NCUA, regulations, regulatory, Regulatory Compliance

I'm violating my own standards by using such an easy topic to blog about but it's too big to ignore.  With the increasing insanity being inspired by 2011's first true hurricane I'd be remiss if I didn't at least explore the impact this is going to have on the business community. I just heard...


July 17, 2011  10:01 PM

Vendor management: What’s missing in this big picture?



Posted by: David Schneier
assessment, Audit, compliance, exam, examinations, GLBA, regulatory, Regulatory Compliance, risk

I do a whole lot of work with vendor management, a fact which most of my regular readers are quite aware of.  And while I typically recoil when somebody else says of themselves what I'm about to say, I'm going to say it anyway; I'm really something of an expert on the discipline, particularly as...


June 15, 2011  4:52 PM

The trouble with ineffective controls



Posted by: David Schneier
assess, assessment, Audit, bank, banking, community bank, compliance, credit union, CU, data center, GLBA, NCUA, regulation, regulatory, Regulatory Compliance, Security

I've been visiting with my mother who lives in a gated retirement community. In order for me to gain access to the development I need to pass through a security check point at the main gate. They ask me who I'm visiting, I provide my mother's name and either they find my name on the pre-approved...


June 3, 2011  3:18 PM

What does the “E” stand for in ERM?



Posted by: David Schneier
assess, assessment, Audit, compliance, enterprise risk, enterprise risk management, ERM, GLBA, NCUA, regulations, regulatory, Regulatory Compliance, risk management

Last week while attending a banking conference I found myself in a conversation about Enterprise Risk Management (ERM).   I had made the comment that I was tired of constantly hearing different definitions of what the discipline is and how it should be applied.  It’s the...


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