Regulatory Reality:

examiner


December 19, 2012  1:51 PM

CFPB: Dodd-Frank at its best.



Posted by: David Schneier
bank, banking, banking crisis, banks, compliance, compliant, Dodd-Frank, economy, exam, examination, examinations, examiner, examiners, exams, Federal Reserve Bank, FFIEC, financial, financial institutions, FRB, mortgage, regulation, regulations, regulations audit, regulatory, regulatory guidance, requirements, risk, SOX, third party management, third party oversight, too big too fail, vendor, Vendor Management, vendor risk, vendor risk assessment, vendor risk rating

The campaign season that ended with last month’s presidential elections generated more debate and rhetoric than any other in my lifetime.  As I'm an outspoken person who has never shied away from a good argument I routinely found myself engaged in exchanges with a remarkably broad range of...

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
assess, assessment, assessments, Audit, bank, banking, CISO, CISSP, compliance, compliance officer, compliant, credit union, credit unions, CU, disaster, disaster recovery, DR, enterprise risk, enterprise risk management, ERM, exam, examination, examinations, examiner, examiners, exams, framework, governance, GRC, guidance, information security, information security office, infrastructure, ISO, oversight, policy, procedure, regulation, regulations, regulations audit, regulatory, regulatory guidance, risk assess, risk assessment, risk assessments, risk management, risk-based, risks, technology

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,...


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 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...


February 3, 2012  5:58 PM

Governance, risk and compliance – related but not the same.



Posted by: David Schneier
Audit, auditor, compliance, controls, exam, examiner, FFICE, GLBA, governance, GRC, internal controls, NCUA, regulations, regulatory, Regulatory Compliance, risk

I was sitting in a meeting this week listening to a group of very bright people talking about an initiative centered on installing a software solution and I realized something rather disturbing; somewhere along the way in our industry governance, risk and compliance has started melting together and...


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...


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...


April 26, 2011  6:00 AM

Is compliance moving too fast?



Posted by: David Schneier
assessment, Audit, compliance, exam, examiner, exams, GLBA, governance, GRC, NCUA, oversight, regulations, regulatory, Regulatory Compliance, risk

I joined a new group last week on LinkedIn focusing on compliance within the banking space and during my first visit answered a forum question that started with "How do you manage the flow of compliance information"?  It was a relevant question and I was happy enough to offer my two cents (never a...


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