From the Field
Enlightenment from recent audits & exams
The Problem with PEN Tests
This is a true story, the names have been changed to protect the guilty. Al Akazam (not his real name) is an IT consultant with a solid background in technology, …
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Examination Downgrades Correlated with Poor Vendor Management
According to Donald Saxinger (senior examination specialist in FDIC’s Technology Supervision Branch) in a telephone briefing given to the ABA in December of last year, almost half of all CAMELS …
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Implementing the CFPB-required Compliance Management System (Part 2)
CFPB compliance examinations have only just started and the agency has already identified deficiencies in some institutions:
“The CFPB has found one or more situations in which an effective CMS …
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Hot Topics
The Guru reflects on recent events
The Financial Institutions Examination Fairness and Reform Act – Redux
This new bill (H.R. 1553) introduced on April 15th is actually a word-for-word duplicate of H.R. 3461 which I wrote about here. The previous bill died in committee, but …
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Court rules in favor of Bank in account takeover case
Unlike the PATCO ruling, a district court in Missouri has ruled in favor of the bank in an account takeover case brought by one of its commercial customers. This case …
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FFIEC Issues Social Media Guidance
(UPDATED – Added link to public comments)
Just out, this document is really a request for comments on the proposed guidance, but final guidance is likely to follow this very …
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About the Compliance Guru
Tom Hinkel has over twenty years experience in IT regulatory compliance, risk management and information security both inside banks and as a consultant for institutions of all sizes, Hinkel also serves as a regulatory compliance resource and certified educator for Safe Systems' bank and credit union clients.
