Regulatory Reality:

general controls

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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...

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...


November 16, 2010  6:07 PM

What is the practical value of compliance policies?



Posted by: David Schneier
Audit, bcp, compliance, general controls, GLBA, NCUA, regulatory, Regulatory Compliance, risk, risk assessment, Security

My practice recently wrapped up an engagement in which we conducted a tabletop test of a client's business continuity plan.  As always with such exercises, it's interesting to find out how much distance exists between what's documented in an institution's policy/program and how business is...


April 23, 2010  10:14 PM

Compliance professionals need thick skins



Posted by: David Schneier
assessment, assessments, Audit, bcp, business continuity planning, controls, framework, general controls, GLBA, IT General Controls, NCUA, Regulatory Compliance, Security, security awareness, Vendor Management

I've often surprised people when it comes to conducting audit/assessment work or developing compliance programs.  Generally speaking I'm a reasonable person who typically exhibits an abundance of flexibility in my day-to-day life.  However when it comes to my career, I tend to be much more of a...


October 29, 2009  5:23 PM

Regulatory compliance bits and bytes



Posted by: David Schneier
assessments, audits, bcp, business continuity planning, disaster recovery, DR, FDIC, general controls, GLBA, NCUA, NCUA Sheila Bair, Pandemic Planning, password, policy, procedure, Regulatory Compliance, risk assessments, SOX

Many years ago I found myself in one of those awkward moments where I needed to pay for something but didn’t have enough cash on hand to cover the bill. Rather than do the smart thing and find an ATM I instead elected to rip through my car and dig up all of the...


September 1, 2009  3:29 PM

IT audits versus reviews



Posted by: David Schneier
Audit, compliance, general controls, GLBA, governance, GRC, IT, ITGC, NCUA, Regulatory Compliance, risk, risk assessment

I had mentioned in my last post a recent conversation with my partner regarding a proposed IT general controls (ITGC) audit. My primary role in our practice is to head up regulatory compliance services which includes audits, assessments and program development; my...


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