Tag: IT Steering

  • Time to re-think the role of the network administrator?

    Traditionally, the network administrator needed to operate at “ground-level”. Network maintenance was highly specialized and problematic, requiring a constant hands-on approach. And in the very early days (when the Guru started… “he who speaks of floppy disks”…) there were few formal training classes, most of what you learned was by trial and error…lots of error!…

  • The IT Strategic Plan – Why, Who, & How

    One of the most common examination findings recently (particularly with the FDIC) has been the lack of an IT Strategic Plan.  I’m not sure why the focus lately (perhaps the shift from the CAMELS “A” to the “M”?), but the concept is certainly not new.  The regulatory mandate for it is found in the 2004…

  • Using Technology to Drive Compliance

    In the past year to year and a half, nearly all of the IT examination findings I’ve seen have in the broad category of “documentation”, or more specifically, lack thereof.  In other words, policies and procedures were satisfactory, but documentation was either non-existent, or insufficient, to demonstrate that actual practices followed policy and procedure. To…

  • A Recurring Theme in FDIC Consent Orders

    If you look at any of the recent FDIC Consent Orders, you will quickly see a common theme.  I randomly pulled a few off the top of the list, and the verbiage was very similar, and in many cases identical: …the Board shall enhance its participation in the affairs of the Bank …the Bank’s board…

  • “Concentration of duties”

    It is not unusual for a community financial institution with limited personnel to have the Information Security Officer (ISO) act as a backup network administrator.  In fact, this is a relatively common practice in an environment where key personnel will typically wear several hats.  And there are practical reasons for this; the ISO is typically…

  • The Control Self-Assessment (CSA)

    If there was a process that was mentioned 43 times in 7 of the 12 FFIEC IT Examination Handbooks, (including 12 times in the Information Security Handbook alone!), would you consider implementing it?  How about if it virtually assured better audits and examinations?  OK, you’re interested, but the last thing you need is to implement…