Reporting Archives - Safe Systems

09 May 2024

2024 05 08 How to Successfully Manage IT Admins

Banks, Credit Unions, Technology Jamie Davis 0 comment

How to Successfully Manage IT Administrators

IT administrators are pivotal in managing daily IT operations that often play a broader role in strategic initiatives within financial institutions. Their responsibilities stretch from maintaining computer infrastructures and leading IT teams to ensuring robust network security. Effectively managing this multidimensional role requires an appropriate balance of empowerment and checks to create a framework that supports operational success and alignment with the institution’s goals. This blog explores integral strategies that can enhance the effectiveness of IT personnel.

Strategy #1: What to Do When an IT Admin Leaves

The departure of an IT administrator presents a unique set of challenges. It is crucial to immediately change passwords and disable accounts, including all administrative or elevated control accounts to secure the network and data. Developing comprehensive offboarding protocols, like documentation of processes and securing all assets, ensures continuity and security.

Strategy #2: Qualities to Look for When Recruiting

Look for candidates with a blend of technical expertise, problem-solving skills, and strong communication abilities. Potential IT Administrators should also demonstrate effective project management skills and adaptability to handle the dynamic needs of a financial institution.

Strategy #3: Expectations within the First 30 Days

The initial days for any new IT administrator should focus on understanding the institution’s IT framework and security protocols. Tasks like security audits, reviewing network infrastructures, and ensuring compliance with existing IT policies are crucial during this phase.

Strategy #4: Ensuring On-going Success

To assess the effectiveness of a new IT administrator, institutions should first monitor their transition. A new IT Administrator must be able to comprehend and efficiently manage the IT infrastructure quickly with minimal interruptions to operations and staff. They must master the basics such as managing controls, installing and reviewing patches, and conducting regular backups and disaster recovery tests.

Strategy #5: Outsourcing During an Absence

To ensure continuity, institutions can outsource critical IT functions during an administrator’s vacation or leave. Services like network monitoring, data replication, and regulatory reporting can be managed by third-party providers, ensuring uninterrupted operation.

Strategy #6: Succession Planning

Effective succession planning is vital, especially for smaller institutions. This strategy involves cross-training staff and partnering with external IT service providers to ensure a seamless transition and continued operation upon the exit of key IT personnel.

Strategy #7: Keeping Up with Current Trends

Staying updated with the latest in security, technology, and regulatory changes is essential for IT administrators. Awareness of emerging threats and technological innovations helps in proactively managing the institution’s IT landscape and compliance posture.

Managing IT administrators involves a strategic approach that not only focuses on filling the immediate gaps but also on long-term operational continuity. Partnering with knowledgeable IT and security managed service providers can offer additional support to enhance the effectiveness of IT personnel and ensure sustained institutional success.

For more details on implementing these approaches, fostering a strong relationship between IT and Information Security teams, and keeping up with changing regulatory guidance, read
7 Strategies for Successfully Managing IT Administrators.

25 Jun 2020

What is My Bank's Cybersecurity Posture Compared to My Peers?

Banks, Compliance, Credit Unions Tom Hinkel 0 comment

What is My Bank or Credit Union’s Cybersecurity Posture Compared to My Peers?

What is My Bank's Cybersecurity Posture Compared to My Peers?

It is important to understand your institution’s cybersecurity posture to find out where you stand in regard to cyber threats and what you need to do to create a more secure environment. It’s a delicate balance because being behind on your cybersecurity posture means your institution is less secure than it should be but being ahead likely means that you are investing in resources that you may not need. Unfortunately, it’s almost impossible to do a true peer-to-peer comparison because there are just too many variables between even similarly sized financial institutions to obtain a useful analysis. Here’s why:

Every Institution Has a Unique Model

When we implement information security or business continuity programs for banks and credit unions, we start with a process called “Enterprise Modeling” where we identify the departments, the processes, and the functions that make up each individual financial institution. What this process typically reveals is that if you model out two financial institutions that look identical in terms of geographic area, demographic customer or member base, size and complexity, the results will almost always be significantly different since each institution has a unique operating model based on their specific services, organization, processes, and technologies.

Cyber Risk Appetite Is a Key Variable

Cyber risk appetite is another factor that often differentiates your institution from your peers. Safe Systems’ Compliance Guru defines risk appetite as “The amount of risk that an enterprise is willing to pursue and accept in order to achieve the goals and objectives of their strategic plan.” For example, let’s say we have two financial institutions that seem equivalent in outward appearance. Based on their strategic plan, one institution has decided to take a more aggressive cybersecurity posture to electronic banking products and the other has decided to take a more conservative approach. Because the level of risk varies by the approach, you simply cannot accurately compare the two institutions.

The Best Way to Evaluate Cybersecurity Posture

At Safe Systems, we recommend allowing your bank or credit union’s information to stand on its own. To truly improve your cybersecurity posture, you must examine where you are based on where you need to be — not where a peer may be in the process. Carefully evaluate your risks (including areas of elevated risk), and the controls you have in place that offset those risks. Then, examine the best control groups to apply against those areas of elevated risk and develop an action plan to take your institution from where you are now, to where you need to be. Then, when you conduct this process again next year, you can demonstrate steady progress to both examiners and your Board.

Holding Steady May Cause You to Fall Behind

In addition, just because your inherent risk profile isn’t increasing from one assessment to the next, this doesn’t necessarily mean your control maturity levels shouldn’t increase. The risk environment is constantly evolving, so holding steady on your controls may actually mean your cybersecurity resilience is decreasing. Making incremental increases in your control maturity levels will help keep you ahead of the latest threats.

For more information about improving your cybersecurity posture, watch the full “Banking Bits and Bytes Super Duper CEO Series,” below.

04 Jun 2020

Banks, Credit Unions, Technology Allison Stahlman 0 comment

I’m New to Banking Technology – What Do I Need to Know?

The reality for the community banking industry is that often, institutions are limited in staff size, especially in IT. As a result, employees are sometimes placed in an IT role without any prior experience and they are forced to learn the “ins and outs” of information technology quickly to ensure that the institution stays in compliance and the IT environment is secure.

This can be a daunting task for a financial institution employee who’s been placed in an IT role for the first time. From our experience working with more than 600 community financial institutions, there are four key steps that someone who’s new to banking technology needs to know to quickly get up to speed on all things IT:

Step 1: Determine the Financial Institution’s Current State

When stepping into an IT role from another department, the first thing you must do is get a strong understanding of the current state of the institution and how the IT infrastructure is set up. Key questions include:

What does the IT infrastructure look like?
What technology is currently in place?
Is there hardware or software that is reaching end-of-life?
Are network schematics and data flow diagrams up to date and accurate?

Look at all the policies and procedures currently in place and understand what management has approved for the information technology program and how the environment is organized. It’s important to know exactly where the bank is from an IT perspective because without this knowledge you won’t be able to troubleshoot potential issues or plan strategically for where the financial institution needs to be to meet compliance guidelines.

Step 2: Review Vendor Relationships and Responsibilities

It is critical to know exactly who is responsible for each IT activity. Many community banks and credit unions use a variety of vendors, including core providers, cloud providers, managed services providers, and others. It’s important to understand which vendors are involved with all your hardware, software, and IT services and review the service level agreements (SLAs) which are typically found in the contract to be clear on what the vendor should be providing to the institution. This is crucial because if an issue arises you need to know if it is your responsibility to handle it internally or if you should reach out to a vendor for support. Make sure you are clear about what the institution’s vendors are responsible for, when to go to them for help, and which activities are your responsibility under the SLA.

Another key part of this role is vendor management. As a new IT admin, you have a shared responsibility for monitoring and managing the institution’s vendors and weighing the risks each one poses to the institution. To keep the network compliant and secure, you need to thoroughly evaluate potential vendors; identify critical vendors and services; implement an effective risk management process throughout the lifecycle of the vendor relationship, and report appropriately to senior management. Some key best practices include:

Developing plans that outline the institution’s strategy;
Identifying the inherent risks of the specific activity, and the residual, or remaining, risk after the application of controls;
Detailing how the institution selects, assesses, and oversees third-party providers;
Performing proper due diligence on all vendors;
Creating a contingency plan for terminating vendor relationships effectively; and
Producing clear documentation and reporting to meet all regulatory requirements.

Having a proactive plan in place will help you effectively manage vendors and have a clear understanding of the level of criticality and risk for each service provider. Properly vetting and managing vendors will reduce risk for the institution, while also ensuring compliance requirements are met successfully.

Step 3: Understand the Institution’s IT Organizational Structure

How IT roles are structured within a community bank or credit union varies by the institution, but many financial institutions have an IT administrator, information security officer (ISO), chief information officer (CIO), and an IT steering committee to support IT activities. It’s important to learn how the institution is set up and understand what the ISO and CIO are responsible for so you can work together to ensure the institution’s environment is operating securely and efficiently. It’s also important to make sure all ISO duties are separated from other IT roles at the institution to maintain compliance with FFIEC requirements.

At some point, every functional area of a bank or credit union touches IT in one way or another so understanding how every system, application, and functional area within the institution operates and relates back to IT enables you to help the staff by troubleshooting the different issues each department may experience.

Step 4. Review Recent Audits and Exams

Another way to determine the current state of the financial institution is to review all recent IT audits and exams. Determine if there were any findings or recommendations made by a regulatory agency and make sure that this has been addressed and remediated appropriately. With this information, you can tell if there are any current issues or pain points and start to make strategic plans or address specific issues as they arise.

Financial institutions are held accountable for FFIEC compliance and must manage regulatory activities including reporting effectively. New IT personnel should become familiar with FFIEC guidance and understand what is required to meet regulatory expectations and perform well on future audits and exams.

With these steps, new IT admins can gain a deeper understanding of information technology and what their key responsibilities are at the financial institution to ensure the community bank or credit union can successfully meet examiner expectations and keep operations running smoothly.

21 May 2020

Banks, Compliance, Credit Unions Jamie Davis 0 comment

The Value of Network Reporting for Community Banks and Credit Unions

With increased cyber-attacks, shared data with third-party vendors, and strict regulatory requirements, community banks and credit unions have high standards to meet for information security. Adequate oversight and network reporting on the information security program is needed to ensure the proper controls are in place and that all stakeholders have visibility into the network.

In a recent webinar, Safe Systems shared some key observations on the need for financial institutions to have better communication and reporting between IT staff, the compliance department, and senior management. Here are a few key points to consider:

Gaps Between IT Staff and ISO/Compliance Teams

In many financial institutions, there is a lack of synergy and communication between the IT department and the information security/compliance team. Many ISOs simply do not have the technical background to fully understand how information is being protected. They tend to be more focused on vendor management, business continuity management, and performing risk assessments and less familiar with how systems are getting patched; if machines have antivirus; or if backups are updated consistently. It can be difficult to communicate effectively if ISOs don’t understand the IT world or don’t have visibility into network reports and the necessary information to do their job.

Oversight to Better Manage Controls

Because bank and credit union IT staff are human, sometimes errors will occur. While financial institutions have many technology solutions that automate IT functions and controls, oversight is required to ensure that the controls are adequate, working, and therefore mitigating risks. Without appropriate oversight, any gaps in the network can lead to a successful cyber-attack. Similarly, a finding during an exam that shows certain controls were implemented ineffectively can also leave the institution vulnerable.

Limited Access to Reports

Too often, when ISOs conduct a review of the information security program, the reports they receive are vague or too technical to decipher the key insights most important to the ISO role. Other key stakeholders, like the Board and senior management, also may need more access to high-level reports to better identify threats, assess risk, and make decisions on the appropriate controls to implement.

Without access to adequate reports, the ISO and other stakeholders can become overly reliant on the IT team to explain what is happening on the network without having the ability to verify that information independently.

To learn more about information security reporting and get a demo of our NetInsight ™ cyber risk reporting tool, watch our webinar, “NetInsight: Trust But Verify.”

07 May 2020

Banks, Credit Unions Jamie Davis 0 comment

How the Cloud Revolutionizes Disaster Recovery for Financial Institutions

Disaster recovery is a concern for all financial institutions, regardless of size or location, and is essential to protecting data, infrastructure, and overall business operations. In addition to having a thorough disaster recovery (DR) plan, community banks and credit unions need to have a solid site recovery environment to facilitate a quick return to normal business operations, in the event of a natural disaster or other disruption.

Cloud disaster recovery solutions are growing in popularity among many community banks and credit unions. However, it is important to understand the key differences in site recovery models to determine the best fit for your institution.

In a recent webinar, Brendan McGowan, Chief Technology Officer at Safe Systems, outlined the three most common site recovery models available to community banks and credit unions today and discussed key considerations when implementing each.

In-House Site Recovery

When using an in-house site recovery model, financial institutions commonly have a virtualized server environment. These machines often run in a VMware vSphere environment which sits on top of a storage array. On the DR side, there is essentially a clone of the production environment to receive the replicated data. This works well for many financial institutions, however, there are a few considerations to keep in mind.

House Site Recovery

With in-house site recovery, you’ll need to:

Have redundant hardware in the DR environment at an additional cost.
Purchase an additional facility like a co-location or branch for DR.
Oversee hardware and software lifecycle management for both production and DR environments.
Set up dedicated connectivity like multi-protocol label switching (MPLS) to point replication to the DR environment.
Conduct regular maintenance to ensure all replications are healthy and perform periodic testing.
Have significant expertise and talent to make sure the system works correctly and consistently.

Cloud Site Recovery

In this model, the production environment remains the same, but the hardware and software used in the DR environment are replaced with a cloud-based solution. With cloud site recovery, financial institutions don’t have to pay for servers and computing time until the day they need to turn on the disaster recovery solution. Until then, the institution will only be billed for the amount of storage it consumes.

Cloud Site Recovery

When you use a cloud site recovery solution like Microsoft Azure Site Recovery, you create a storage pool to receive replication from a small server on-premise, which is the cloud site recovery replication server. The replication server works by having each of your production servers send its data changes in real-time to the cloud application server. This server is compressing, encrypting, and deduplicating all of the incoming data and continuously shipping it securely to your cloud site recovery storage pool.

With the cloud site recovery model, you no longer have to:

Deal with redundant hardware on the DR side since everything is stored in the cloud.
Manage hardware and lifecycle management on the DR-side.
Pay for separate facilities since the data is in the cloud, and you can store your data anywhere in the world.
Worry about dedicated connectivity because you can send all of the replication over the internet with a simple virtual private network (VPN).
Handle all of the maintenance or have the expertise required to run the system.

Cloud-Native Resilience

In the cloud-native site recovery model, both the production and disaster recovery environments are in the Cloud. To set up the cloud environment, using Microsoft Azure, for example, you can sign up for Azure Virtual Machines, which would correlate to VMware vSphere in your environment. After that, you can set up your production virtual machines.

Cloud-Native Site Recovery

At this point, you can register for cloud site recovery for your institution’s individual virtual machines. Once you’ve selected your machines for replication, the system automatically moves that data to whichever Azure zone you select so you get to choose some zone disparity.

In the cloud-native resilience model:

There is no Azure site replication server as there was in the cloud site recovery model.
Since both environments are cloud-native, all the data is in the cloud and you need not worry about a replication server. Simply check a box to turn it on.
In addition, file backup is also a simple checkbox for each server, providing you the option to choose the location to store the data.

Migrating to cloud-based services is a great option to reduce maintenance; significantly speed up the disaster recovery process; and improve overall operations for your institution. If you are interested in implementing a cloud-based disaster recovery solution, Safe Systems can help you determine the right environment for your institution.

To learn more about disaster recovery and moving to the Cloud, watch our recorded webinar, “The Cloud: Recovery and Resiliency is Just a Click Away.”

01 May 2020

Banks, Credit Unions, Technology Brendan McGowan 0 comment

Combating Business Email Compromise and Protecting Your Remote Workforce

Over the last two months, there have been more people working remotely than ever before, and with more being done outside the branch, financial institutions cannot rely on their usual firewall and anti-malware solutions to protect their staff. Today, the single most common attack used to target remote users is what is known as “business email compromise” (BEC).

Safe Systems hosted a live webinar earlier this month discussing how BEC works; the main techniques used in these types of attacks; and the cost-effective solutions needed to mitigate them. In case you missed it, here are a few key points from the webinar:

What is business email compromise and how does it work?

Business email compromise is a security exploit where an attacker targets an employee who has access to company funds or other non-public information and convinces the victim to transfer money into a bank account controlled by the attacker.

These attacks have two main categories:

Phishing emails – this is just a spoofed email that seemingly comes from someone you trust within the organization (like the CFO or CEO) instructing an employee to wire money to a specific account.
Account takeover – the attacker procures your real username and password and then logs into your mailbox where they are then able to send and receive emails at will from your actual account.

Using these attack methods, cybercriminals can commit many different types of fraud, including wire fraud, non-public information (NPI) theft, and spreading of malware.

There are also a number of different attack “types” that cybercriminals commonly use to take over accounts:

A single-stage attack is a social engineering email directing a user to complete a certain action. For example, an email may include a link that leads to a rogue website where the attacker is trying to capture login information. This is a fairly simple, one-step attack.

The more sophisticated variation on this type of attack is the multi-stage method. In this attack, we often see that instead of having a link in the email that goes to a suspicious website that could potentially be blocked by other security layers, attackers use a link in the email that goes to a highly trusted place like a Citrix share file or some other trusted site. If the user clicks the link, they’ve now stepped outside of any email security layers the institution might have in place. Most often these sites are SSL encrypted so this underscores the importance of having SSL inspection performed on your traffic to ensure links in emails do lead to legitimate, secure websites. The problem with this, however, is that it can be an increasingly difficult job for some financial institutions to implement and manage.

How Can Financial Institutions Defend Against These Threats?

Prevent

The first line of defense against business email compromise is to stop the user from being exposed in the first place, and the single most effective measure financial institutions can implement is user training. It’s important for financial institutions to regularly conduct penetration testing and use security awareness training to educate their employees. Over the years, we’ve seen a distinct correlation between the frequency of user security awareness training and the success rate of phishing attacks. Some institutions leverage self-testing tools such as KnowBe4, but there are many other services that financial institutions can use to test their employees.

Mitigate

The second line of defense is to stop the user from causing damage. To mitigate the threat, financial institutions can use a variety of effective tools, including:

Email Filtering – a tool that filters out suspicious emails to ensure no spam, malicious content, or sensitive data makes it out of the institution unauthorized.
DNS Filtering – is the process of using the Domain Name System lookup to find the IP address of a website to block malicious websites and filter out harmful or inappropriate content.
URL Rewrite – if an email has a link, the system rewrites the destination of the link to go to a security company first before the real session is connected.
Multifactor Authentication – this tool requires more than one method of authentication to verify a user’s identity for a login or other transaction. The methods include something you know (pin); something you have (phone) and/or something you are (biometrics).

These are just a few of the tools that can help strengthen your institution’s security posture and ensure users do not fall victim to malicious attacks. However, if they do, it is critical to have a plan to respond.

Respond

The last line of defense is to stop the expansion of damages if a threat has occurred. In this case, financial institutions must conduct an investigation into the cyberattack and have thorough logs of their mail system to understand exactly what occurred; how far it has spread; and determine the next steps. Community banks and credit unions should have an incident response plan in place and perform regular tabletop testing to confirm the plan works and will be useful when a real attack occurs.

To learn more ways to protect your institution from business email compromise, watch our recorded webinar, “Business Email Compromise – Preventing the Biggest Risk from Remote Users.”

23 Apr 2020

Banks, Credit Unions, Technology Jamie Davis 0 comment

Managing Banking IT Operations During a Pandemic: Your Top Questions Answered

For many financial institutions, it has been a challenge to keep IT operations moving efficiently during this pandemic. Since community banks and credit unions are considered an essential business, they are required to continue to serve customers and members. This can be difficult when employees are unavailable or are forced to work remotely from their homes for the first time. Many financial institutions have questions about how to efficiently manage their remote workforce, while keeping the institution secure and employees, customers, and members safe.

To address these questions, Safe Systems’ Information Security Officer, Chuck Copland, VP of Compliance Services, Tom Hinkel, and Chief Technology Officer, Brendan McGowan held a live panel discussion last week covering ways financial institutions can manage banking IT operations during a pandemic. In this blog, we’ll cover a few of the top questions from the panel:

1. How would you suggest making sure that remote access vendors are vetted quickly but thoroughly?

For many financial institutions, remote access was limited before the pandemic because this technology either didn’t support critical functions or wasn’t a priority at the time. Now, remote access is very important to continue business operations efficiently, and many community banks and credit unions are evaluating options for larger scale use. To do this effectively, you first need to consider all of the risks associated with remote access and the potential impact on your organization. This helps you get a quick baseline of the controls you’re going to require, which will then inform your vendor review.

While some institutions may be in a rush to get remote access tools up and running, it is important to stick to your normal vendor review process and take the time to thoroughly evaluate third-party risk. If you do have to sacrifice the integrity of your normal due diligence process and cut some corners to choose a vendor quickly, understand that there will be a resulting change in your institution’s risk appetite, or your acceptable risk. Make sure this is updated and that the executive management team including the Board sign off on the your new risk appetite.

2. What are some lessons learned about remote access for financial institutions during this pandemic?

It can be difficult to determine which remote access tool fits best with your institution’s unique security and regulatory needs. First, you should identify the best way for your staff to access the network whether it’s through a virtual private network (VPN) or an application for remote access, like a telecommute remote control tool. A VPN is a piece of software that lives on a computer that your user has at home — preferably a bank or a credit union asset and not their personal home PC.

When a user connects through a VPN tunnel, typically the computer gives access to the local network at the institution. With telecommute remote control tools, like LogMeIn and Splashtop, the user is working from a local computer at the office. These tools limit the abilities of the computer from interacting with the institution’s local network, often, making it a secure option for organizations that don’t want employees to have direct access to the network. Because each tool achieves a different goal, you will want to determine exactly what your team needs to conduct remote work efficiently, effectively, and securely.

There are also several collaboration tools and meeting tools to consider which can help different teams within your institution communicate and collaborate on projects internally and meet with each other or speak with external users outside of your organization.

What are you hearing from examiners? How are exams continuing during the pandemic?

We’re seeing that all examinations have either been pushed back to a later date or changed to a remote visit. In the climate that we are in, examiners are expecting institutions to make accommodations to customers that may be negatively affected by this pandemic and ensure they have access to other critical products and services.

But what happens when the dust settles, and we go back to a more normal set of circumstances? What will examiners expect then?

Most likely, we expect them to be looking for a mature “lessons learned” document that financial institutions create to show what they have learned over the course of this particular pandemic event. We can certainly see guidance changes coming out of this, with regulators having a new set of expectations for financial institutions going forward. Right now, we are all concerned with just getting through this challenging time but all financial institutions need to document what they are doing and the lessons they have learned along the way. They also need to create a report for the Board and the executive management team recommending any necessary changes to mitigate the impact of a pandemic, should one happen again in the future.

If you’d like to find out what other questions were answered during the live panel, watch our recorded webinar, “Ask Our Experts: Managing Banking IT Operations During a Pandemic.”

16 Apr 2020

Banks, Compliance, Credit Unions Tom Hinkel 0 comment

Building a Pandemic Response Plan: What Are the Requirements for Community Banks and Credit Unions?

Building a Pandemic Response Plan

As COVID-19 continues to spread around the world, financial institutions have been forced to respond to this pandemic in new and innovative ways to stop the spread of the virus; protect their employees and the public; and keep their doors open and operations running smoothly to serve their customers and members. Community banks and credit unions are referencing the Pandemic sections of their business continuity management plans to determine the best way forward for their institutions during this challenging time. With the Federal Financial Institution Examination Council’s (FFIEC) recent business continuity management (BCM) guidance, many financial institutions are first of all wondering what has changed in the guidance, and second what specific additional changes this particular event might require.

Pandemic Planning

Since 2007, financial institutions were required to have a separate pandemic plan, and regulators only looked for documentation that institutions were testing their plans periodically. Unfortunately, the pandemic section of the business continuity plan (BCP) has tended to be treated as more of an afterthought since these situations have historically occurred much less often than natural disasters or other business interruptions. If they were assessed at all, they fell into the category of a high impact, low probability event.

Notwithstanding COVID-19, pandemics are still low probability events, but the impact of these events may be far more significant than past risk assessments have indicated. In what may now be perceived as an untimely move, the FFIEC made the decision in the 2019 BCM update to deemphasize Pandemic by categorizing it the same as any other disruptive event. The FFIEC no longer requires financial institutions to have a separate pandemic plan, but instead expects community banks and credit unions to assess and manage pandemic risk alongside all other possible disasters.

In other words, your BCM plan is your pandemic plan, and you must analyze the impact a pandemic can have on your organization; determine recovery time objectives (RTOs); and build out a recovery plan. You must also include a methodology to determine the key triggers your organization will use to activate your recovery plan when faced with a pandemic. But when should you activate your recovery plan and who is in charge of this process?

Pandemic Response

Before a recovery plan is activated, it is important to have an initial response team (typically comprised of C-Level executives) evaluate the situation and assess the potential impact of the current event on the institution. The team must determine if the situation is likely to negatively impact the institution’s ability to provide products and services to their customers or members beyond the established recovery time objectives outlined in the BCM plan.

The same rules apply in a pandemic. Community financial institutions should use the six pandemic phases outlined by the World Health Organization (WHO) or the Center for Disease Control (CDC) to evaluate the severity of the situation.

In most cases, the pandemic portion of the plan is not triggered for activation until phases 4-5 (or if between 20-40% of your workforce is not available to work).

What Regulators Expect

During a pandemic, regulators expect financial institutions to continue offering products and services to customers/members and conduct operations as normally as possible. This underscores the importance of including succession planning and cross training in the BCM plan. In the past, assumptions used to simulate a pandemic were that phases 4-5 wouldn’t last more than a week or two, so most financial institutions may only have planned for one person to be identified and pre-trained to step into a critical role until the event was over. However, the COVID-19 pandemic is a global crisis currently impacting at least 183 countries and territories and is predicted to impact many more people, and take much more time to contain.

To ensure critical functions continue, financial institutions should have at least two or three alternate staff members trained for every primary resource within the institution and assess whether some roles can be performed remotely. This can be difficult for smaller institutions with limited staff and resources. For specialized functions dominated by key personnel, such as funds management, wire services, human resources, etc., these institutions may not have multiple alternatives to step in if key employees are unavailable. In these circumstances, you may need to have other cross-trained staff members identified who can step into these roles quickly.

Next Steps: Lessons Learned

There will be many more lessons learned after the COVID-19 pandemic has passed, and regulators will expect those lessons to be reflected in your plan. When all is said and done, regulators are likely to ask “what have you learned from this event, and what have you done to enhance your pandemic plan based on those lessons learned?” Prior to this event, had you analyzed your business processes and their interdependencies, and prioritized them by recovery time? Since interdependencies include employees, and pandemic events almost exclusively impact personnel, have you identified employees with job duties capable of being performed remotely? If so, did they have secure, reliable, remote access? If those job duties are highly specialized, or highly critical, did you have alternate personnel identified and pre-trained to step in when needed?

The answers to these questions, and many more, will be used to enhance the pandemic section of your BCM plans, but until we reach that post-event, lessons-learned point, it’s important for financial institutions to continue to reference their business continuity plans; document the entire process; keep stakeholders informed; and put measures in place to continue serving their customers and members and protecting their employees and the public.

For more information on pandemic response, view our pandemic resource center. Or, if you would like to make sure your BCM is up to date, please request a complimentary plan review to ensure that your business continuity management plan is keeping up with changing regulations.

View Our Pandemic Resources

09 Apr 2020

Banks, Compliance, Credit Unions Christine Ray 0 comment

American Pride Bank Tackles Information Security Responsibilities with Safe Systems’ ISOversight Virtual ISO Solution

With ongoing cybersecurity threats; increased use of third-party providers; and constantly evolving regulatory and reporting requirements, the role of the information security officer (ISO) is even more important in today’s complex banking environment than ever before. However, community bank and credit union ISOs often struggle to keep up with the growing number of responsibilities this role requires – often forced to manage critical tasks with limited resources and a lack of segregation of duties.

The Challenge

Nicole Rinehart, Chief Operations Officer at American Pride Bank, ran into this very issue as the sole IT admin at American Pride Bank. Managing all of the ISO responsibilities, including critical activities such as Board reporting and the production of comprehensive reports for examiners, was difficult to manage due to the many manual processes required.

During a regulatory examination, an examiner recommended the bank focus on having more independence within its ISO duties. The Federal Financial Institution Examination Council (FFIEC) states that all financial institutions must have separation of duties for the ISO role. To accomplish this, the bank began evaluating solutions to help streamline processes and ensure complete oversight of all information security activities.

The Solution

Implementing a Virtual ISO to Improve Compliance Posture Complimentary White Paper

After consideration, American Pride Bank decided to partner with Safe Systems and implement its ISOversight virtual ISO solution. The service includes a suite of applications and programs to help institutions streamline management of key compliance duties including the CAT, BCP, Vendor Management and Information Security.

In this case, the bank was already leveraging individual components of ISOversight. By converting to the virtual ISO service, they gained additional tools, reports, and expert compliance support. An important part of the solution includes monthly meetings with the Safe Systems compliance team to assess the bank’s information security activities and provide guidance.

The Results

With ISOversight, American Pride Bank has improved its overall preparation and communication of the information security program. All key stakeholders in the bank have access to ISO-related items in real-time, and the information security program is more organized and streamlined, enabling the bank to save time on monitoring and reporting.

“The ISOversight solution has been a game-changer for our bank because now we have a robust process in place working with Safe Systems and a full committee of our team members to ensure all tasks are completed accurately and nothing slips through the cracks,” said Rinehart. “It’s so important to have a process like this, especially when you have limited resources. Safe Systems has truly become an extension of our internal team, helping us to stay on track with ISO responsibilities and ensuring we comply with all regulatory requirements.”

To learn more, read the full case study, “American Pride Bank Streamlines Processes and Improves Compliance Reporting with Safe Systems’ ISOversight Virtual ISO Solution.”