Regulatory Reality:

community bank

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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 30, 2012  3:09 PM

Hurricane Sandy: An epic storm and the ultimate DR test



Posted by: David Schneier
Audit, audits, backup, bank, bank closing, bank closings, banking, banks, BIA, business, business continuity, business continuity plan, business impact analysis, community bank, disaster recovery, DR, examiners, internal audit, internal controls, ITGC, NCUA, pandemic, Pandemic Planning, policy, procedure, risk assess, risk assessment, risk assessments, risk management, risks

I've written similar posts in that past where I start off by apologizing for appearing opportunistic when leveraging a significant news event to generate site content.  However when considering roughly one-third of all my clients are dealing with Hurricane Sandy this represents a rare chance to...


October 22, 2012  2:09 PM

Are banks unfairly scrutinized?



Posted by: David Schneier
ACH, assess, assessment, assessments, Audit, auditor, audits, banking, banks, business, CISA, CISO, community bank, compliance, credit unions, CU, exam, examination, examinations, examiner, examiners, exams, FFIEC, financial institutions, general controls, GLBA, identify theft, identity theft, information security, information security office, Information Technology General Controls, internal audit, internal controls, ITGC, NPPI, observations, oversight, personally identifiable informaiton, PII, privacy, risk assess, risk assessment, risk assessments, risk management, risk-based, risks

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...


August 8, 2012  6:21 PM

Metrics Reporting: Are pretty colors always pretty accurate?



Posted by: David Schneier
Audit, auditor, audits, bank, banking, banks, Board, Board of Directors, BoD, business, community bank, compliance, control, controls, exam, examination, examinations, examiner, examiners, exams, financial institutions, fraud, governance, regulation, regulations, regulations audit, regulatory, regulatory guidance, SOX

I have an odd relationship with management reporting.  I know it's a necessity and quite often see clear value in what's packaged for senior management and board review.  But a significant piece of the reporting content comes in the form of metrics and, well, whenever I hear the term it conjures...


July 29, 2012  6:39 PM

Credit Card Breaches: The times they need a changin’



Posted by: David Schneier
ATM, bank, banking, banks, breach, checking account, community bank, credit, credit card, cyber security, data security, evidence, financial institutions, hack, hacker, hackers, hacking, id theft, identity theft, information security, network, oversight, PCI, personally identifiable informaiton, PII, regulation, regulations, Security, security breach, theft

If my blogging about credit card breaches has a bit of a deja vu feel to it you're not crazy, I last touched on it less than six months ago.  Sadly I was handed a new update this week in the form of my bank card being cancelled from right out underneath me again.   For those of you keeping score...


July 21, 2012  8:25 PM

CFPB: Filling the regulatory void left by Sheila Bair



Posted by: David Schneier
Add new tag, assess, assessment, assessments, bank, banking, banking crisis, banks, community bank, compliance, compliance officer, compliant, control, credit, credit card, data security, Dodd-Frank, economy, enterprise risk, enterprise risk management, ERM, exam, examination, examinations, examiner, examiners, exams, Federal Reserve Bank, FFIEC, financial, financial institutions, framework, information security office, lending, LinkedIn, mortgage, NCUA, NCUA Sheila Bair, NPPI, observations, oversight, personally identifiable informaiton, PII, policy, privacy, procedure, regulation, regulations, regulations audit, regulatory, regulatory guidance, risk assess, risk assessment, risk assessments, risk management, risk-based, risks, security PII, Sheila Bair, social security numbers, technology, third party management, third party oversight, vendor, Vendor Management, vendor risk, vendor risk assessment

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...


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...


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