Regulatory Reality:

GLBA


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...

April 18, 2011  6:22 PM

Epsilon: Why vendor management is critical.



Posted by: David Schneier
Audit, bank, banking, compliance, FDIC, FFIEC, GLBA, NCUA, regulatory, Regulatory Compliance, requirements, risk, SAS 70, vendor, Vendor Management

A few years back we hired a local painting contractor to do some work around my house.  Upon completing his sales spiel he announced that he often relies upon subcontractors for the less skilled work and wanted to be upfront about that before we entered into any sort of deal with him.  Anyone he...


April 8, 2011  10:45 AM

GRC is about to see its future.



Posted by: David Schneier
Audit, compliance, GLBA, governance, GRC, HIPAA, PCI, regulations, regulatory, Regulatory Compliance, risk, SOX, UCF

After nearly a quarter century of working in and around the corporate IT domain I have a grand total of four bold predictions I've made that stand out.  Three of them I had nailed dead on and the fourth never panned out a fact that confounds me still to this day. The...


March 25, 2011  2:48 PM

A Hard Lesson Learned in Japan’s Disaster



Posted by: David Schneier
business continuity, business continuity plan, business continuity planning, disaster, disaster recovery, FFIEC, GLBA, NCUA, regulations, regulatory, Regulatory Compliance, Security

There will be no shortage of industry articles and analysis that will emerge from the horrific events in Japan over these past few weeks, that's for certain.  This is arguably the most significant event to hit a major regional economy since World War II and it's important to learn as many lessons...


March 15, 2011  9:58 PM

Is your examiner a friend or foe?



Posted by: David Schneier
Audit, bank, banking, compliance, credit union, CU, exam, examiner, FDIC, GLBA, NCUA, OCC, oversight, regulations, regulatory, Regulatory Compliance

I was catching up on my industry emails the other day and buried in my FDIC email folder was Financial Institution Letter FIL-13-2011, sent out on March 1st. Truthfully I usually pay close attention to their Friday afternoon blasts regarding bank closings and only skim the rest. But this one...


January 29, 2011  1:34 AM

Regulatory compliance is not easy



Posted by: David Schneier
assessment, Audit, bcp, business continuity plan, disaster recovery, DR, FDIC, GLBA, NCUA, regulations, regulatory, Regulatory Compliance

Something happened within our practice this past week that made me recall a story from the very beginning of my audit and compliance career. Way back in 1998 when I was first transitioning from being an application developer/manager to a compliance/audit professional, my first long term engagement...


January 17, 2011  1:55 PM

Is the U.S. banking crisis over?



Posted by: David Schneier
bank closing, bank closings, banking, banking crisis, compliance, FDIC, FFIEC, foreclosure, GLBA, NCUA, regulatory, Regulatory Compliance

As my professional mind started winding down this evening in anticipation of the weekend, my thoughts started drifting towards yard work and time with the family. Then my Droid started chirping it's little sing-song of alerts as a round of emails hit my inbox and I was brought back to reality for a...


January 8, 2011  5:41 PM

New year advice on developing a business continuity plan



Posted by: David Schneier
Audit, bcp, BIA, business continuity plan, business impact analysis, exam, examiners, FFIEC, GLBA, regulatory, Regulatory Compliance, risk, risk assessment

One of the first things I had to work on this week (and thus one of the first things to work on in the new year) was finalizing a report from last year. The report covered the results of a Business Continuity Plan desktop test and the client needed some clarifications around the results. I've...


December 28, 2010  8:55 PM

Risk versus reward: Data warehouses and the cloud



Posted by: David Schneier
assessment, Audit, cloud, cloud computing, data security, data warehouse, GLBA, PCI, regulatory, Regulatory Compliance, SOX

It's a popular time of the year for people like myself who publish any form of content to either reflect on the year that was or make predictions on the year that's to be. Confidentially those are typically easy pieces to write and I'm generally happy to take advantage of such opportunities....


December 10, 2010  6:45 PM

Year-end begets regulatory compliance audit panic



Posted by: David Schneier
assessment, Audit, FFIEC, GLBA, PCI, red flags, red flags identity theft, regulatory, Regulatory Compliance, Security, security awareness, SOX

Sometime back in August I blogged about addressing outstanding compliance tasks before the year's end. We see it every year in my practice: Compliance  and security folks wake up sometime right around now in a bit of a panic and realize that they're about to miss hitting on certain key regulatory...


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