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Vendor Management in 3 Parts. Part 3 – Risk Management (or, “can we or can’t we?”)
The last step in the vendor management process is to manage, or control, the risk that was identified in step 1, and assessed (as inherent risk) in step 2. Controlling risk is defined as applying risk mitigation techniques (or “controls”) to reduce risk to acceptable levels It’s important to understand that risk can never be completely eliminated,…
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FFIEC Handbook Update – SAS 70 Transition
The FFIEC has just updated their online IT Examination InfoBase to address the AICPA phase-out of the SAS 70 reporting format. All references to “SAS 70” have now been replaced, and the SAS 70 sections of the Audit and Information Security Handbooks have been completely removed. Previously there were a total of 31 references to…
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SOC 2 vs. SAS 70 – 5 reasons to embrace the change
The SOC 2 and SOC 3 audit guides have recently been released by the AICPA, and the SAS 70 phase-out becomes effective tomorrow. The more I learn about these new reports the more I like them. First of all, as a service provider to financial institutions we will have to prepare for this engagement (just…
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Vendor Management and the SAS 70 Replacement
I’ve written about the replacement for the SAS 70, which officially phases out on June 15th, previously. But because this one report is being replaced with 3 new reports, financial institutions have an additional challenge that they didn’t have before. Your vendor management program must now determine the most appropriate report to request based on…
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SOC Report Selection & Evaluation Aids
With the SAS 70 phasing out on 6/15, financial institutions have a dual challenge; determining the best report to request, and evaluating the report they are provided. To assist with this challenge, I’ve created two documents. The first, or Step 1, is a SOC Selection Flowchart, which is available here. This will assist in determining…
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AICPA finalizes SAS 70 replacement
I wrote about this here as well, but it’s now official: The AICPA has clarified the SAS 70 replacement reports. They are actually officially being referred to as “Service Organization Control Reports (formerly SAS 70 reports)”. The new SOC reports provide a framework for auditors to examine controls and to help senior management understand the…
