Regulatory Reality:

GLBA


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...

October 26, 2011  8:36 PM

Who examines the examiners?



Posted by: David Schneier
assessment, bcp, business continuity plan, GLBA, NCUA, NCUA Part 748, regulations audit, regulatory, Regulatory Compliance, risk, risk assessment, Vendor Management

I remember conducting a risk assessment a few years back for a credit union in which they were missing just about every artifact necessary to prove compliance with NCUA Part 748 (if you're not already aware, thats GLBA for credit unions).  It was, for lack of a better term, a...


October 3, 2011  10:39 PM

Dodd-Frank Section 165(d) : Is this really what was needed?



Posted by: David Schneier
bcp, business continuity, business continuity plan, compliance, Dodd-Frank, FDIC, GLBA, NCUA, regulations, regulatory, Regulatory Compliance, too big too fail

Ever since Dodd-Frank legislation first started rolling down the turnpike towards the banking industry I've been reading and listening to all manner of rhetoric about how none of it's going to solve any problems, that it's going to impede the business of banking and force money to be deposited and...


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 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...


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...