2 min read
Ruminations on the New Dodd-Frank Section 1033 Rule
When the Dodd-Frank Act was passed in 2010, it included Section 1033. This section required the Consumer Financial Protection Bureau (CFPB) to create...
Governance
2 min read
Demystifying Policy, Procedures, and Standards: Understanding the Differences Matters
In every aspect of life, from managing a company to navigating through traffic, guidelines play a crucial role in maintaining order and achieving...
2 min read
Should Financial Institutions have a BISO Program?
A BISO (Business Information Security Officer) is an ombudsman for business lines across an institution. This person is responsible for representing...
2 min read
The FDIC InTREX Gets Audited
While the FFIEC has released three major guidance updates since July 2019, the FDIC has not updated its examination program to include the newer...
1 min read
Outsourcing IT
It’s common practice for financial institutions to outsource some or all of their Information Technology (IT) functions to a Managed Service Provider...
3 min read
Change, Conflict and Culture
We have many institutions either going through or coming out of a large amount of change. It seems like there’s always some new guidance, product, or...
2 min read
Confessions of a Professional Worrier
A few weeks ago, in my life outside of cybersecurity, a person said to me: “You are always thinking three steps ahead of the rest of us”. I am not...
2 min read
What Does it Mean to be a Good Partner?
While the definition of a partner is fairly broad, its principles apply to a very broad spectrum of relationships. In the cybersecurity realm, this...
2 min read
Managing the Relationship Between Information Technology and Information Security
It’s easy to use the terms “Information Technology (IT)” and “Information Security (IS)” interchangeably. They are equally important but serve...
2 min read
Meaningful Governance
Most information security professionals understand the compliance and business requirements of keeping management informed of the Information...