Regulatory Reality:


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...

August 15, 2011  8:45 PM

NCUA vs. Wall Street: Who’s going to win?

Posted by: David Schneier
cdo, compliance, foreclosure, NCUA, regulations, regulatory, Regulatory Compliance

I had the good fortune to rediscover a recent favorite book while driving to a client engagement last week.  It was the audio version of Michael Lewis’s “The Big Short”.  I had first listened to it last year and thought at the time it was about as good a...

August 3, 2011  6:16 PM

Are you security unaware?

Posted by: David Schneier
compliance, GLBA, NCUA, NPPI, PII, regulatory, Regulatory Compliance, Security, security awareness

When I first started blogging professionally a colleague of mine cautioned that I should avoid posting anything where a client might recognize themselves in any story or example I might relate, good or bad.  And so in the years since I've gone to sometimes great length to anonymize my content to...

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...

July 8, 2011  3:16 AM

Cloud Computing – at what price?

Posted by: David Schneier
cloud, cloud computing, compliance, regulatory, Regulatory Compliance

Years ago while working on SOX in its early days the team I managed started getting just a little tired of hearing that very term.  It seemed that everything was "SOX-this" or "SOX-that" as everyone was trying to attach themselves to the massively intrusive new regulation and establish that they...

June 24, 2011  2:43 PM

Is new guidance really new or worth waiting for?

Posted by: David Schneier
cloud, compliance, compliant, FDIC, FFIEC, guidance, NCUA, PCI, regulatory, Regulatory Compliance, regulatory guidance

Oh how the times have changed.  Once upon a time I was part of a group of peers who waited for new album releases, camped out over night for concert tickets and once even waited on line for the annual release of Strat-O-Matic's baseball set (perhaps the nerdiest thing I've ever done).  And all of...

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...

May 20, 2011  3:29 AM

Does the banking industry understand what risk-based means?

Posted by: David Schneier
compliance, FFIEC, GLBA, regulation, regulations, regulatory, Regulatory Compliance, risk, risk assessment, risk-based

Years ago I added an addition to my first house. After my second child arrived, we had simply run out of room and decided it was easier to expand our current living space rather than trying to find a bigger one. Plans were drawn up, work scheduled and money deposited. Two days before the first...

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