Regulatory Reality:

risk assessments

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March 6, 2013  5:19 PM

Security Standards: What’s in a name?



Posted by: David Schneier
assess, assessment, assessments, Audit, auditor, audits, CISO, community bank, control, controls, credit union, credit unions, data security, framework, information security, information security office, infrastructure, ISO, risk assess, risk assessment, risk assessments, risk management, risk-based

I had an interesting phone call recently with someone in a CISO-type position.  They were looking for a consultant to help them keep a seat warm working with information security risk assessments and were hoping to find a resource with practical experience using the NIST 800-53 standard.  It was...

October 30, 2012  3:09 PM

Hurricane Sandy: An epic storm and the ultimate DR test



Posted by: David Schneier
Audit, audits, backup, bank, bank closing, bank closings, banking, banks, BIA, business, business continuity, business continuity plan, business impact analysis, community bank, disaster recovery, DR, examiners, internal audit, internal controls, ITGC, NCUA, pandemic, Pandemic Planning, policy, procedure, risk assess, risk assessment, risk assessments, risk management, risks

I've written similar posts in that past where I start off by apologizing for appearing opportunistic when leveraging a significant news event to generate site content.  However when considering roughly one-third of all my clients are dealing with Hurricane Sandy this represents a rare chance to...


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...


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,...


July 21, 2012  8:25 PM

CFPB: Filling the regulatory void left by Sheila Bair



Posted by: David Schneier
Add new tag, assess, assessment, assessments, bank, banking, banking crisis, banks, community bank, compliance, compliance officer, compliant, control, credit, credit card, data security, Dodd-Frank, economy, enterprise risk, enterprise risk management, ERM, exam, examination, examinations, examiner, examiners, exams, Federal Reserve Bank, FFIEC, financial, financial institutions, framework, information security office, lending, LinkedIn, mortgage, NCUA, NCUA Sheila Bair, NPPI, observations, oversight, personally identifiable informaiton, PII, policy, privacy, procedure, regulation, regulations, regulations audit, regulatory, regulatory guidance, risk assess, risk assessment, risk assessments, risk management, risk-based, risks, security PII, Sheila Bair, social security numbers, technology, third party management, third party oversight, vendor, Vendor Management, vendor risk, vendor risk assessment

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...


April 29, 2012  7:43 PM

Internal Audit: Whose side are they on anyway?



Posted by: David Schneier
assessment, assessments, Audit, compliance, control, control owners, controls, findings, GLBA, internal audit, NCUA, regulations, regulatory, Regulatory Compliance, risk, risk assessments, risks

My first encounter with an auditor was back in the mid-90's while working as an application project manager for a Fortune 100 company.  The group responsible for change management was going through an audit of their process and one of the changes that was selected for review happened to belong to...


December 5, 2011  11:54 PM

The trouble with GRC.



Posted by: David Schneier
assessments, Audit, compliance, governance, GRC, regulations, regulatory, Regulatory Compliance, regulatory guidance, risk, risk assessments

I love GRC, at least the concept.  I've gotten way more than my fair share of print time expounding on its many virtues and how it continues to make inroads into so many organizations.  It's the next and necessary step in the evolution of audit and compliance, a fact (yes, fact) of which I'm...


May 21, 2010  1:55 PM

The new Senate finance bill: not what I hoped for



Posted by: David Schneier
Audit, compliance, FDIC, OCC, Regulatory Compliance, risk, risk assessment, risk assessments, SEC

I'm an optimist:  Ask anyone who knows me either personally or professionally and they'll agree.  And I've been eagerly anticipating new legislation ever since the banks spiraled out of control and needed government intervention to save themselves.  As my wife likes to tell people, when the...


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...


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