Regulatory Reality:

Regulatory Compliance


November 18, 2011  12:22 PM

Why vendor management is a big GLBA deal.



Posted by: David Schneier
assessment, Audit, compliance, FDIC, Federal Reserve Bank, FRB, GLBA, NCUA, OCC, OTC, regulations, regulatory, Regulatory Compliance, risk, risk assessment, vendor, Vendor Management, vendor risk, vendor risk rating

I don't think I'm due to post about vendor management again at least until January 2012 (I try to limit topics to twice a year) but I've had something kicking around my head for a few days now and it needs a proper vetting. Does anyone know why vendor management is such a big issue for banking...

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 13, 2011  10:42 PM

Does everyone value their privacy or is it just me?



Posted by: David Schneier
compliance, Facebook, identify theft, LinkedIn, NPPI, PCI, PII, privacy, regulatory, Regulatory Compliance, Security

I just came to find out that I’m old.  It was somewhat sudden and sort of unexpected as I’m not quite half way to one hundred and have fooled myself into thinking that old doesn’t roll in until somewhere beyond sixty.  But apparently one persons middle-aged...


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 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...


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