The Federal Financial Institutions Examination Council (FFIEC) plays a crucial role in establishing standards and guidelines to ensure the security and resilience of financial institutions. We are just covering a 50,000-foot overview of FFIEC regulations around cybersecurity and the due diligence that needs to be performed annually. We will look at additional annual requirements in the future.
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FFIEC Cybersecurity Regulations
The FFIEC has developed a comprehensive framework to help financial institutions manage and mitigate cybersecurity risks.
Key components of the FFIEC’s cybersecurity regulations include:
- Cybersecurity Assessment Tool (CAT): The CAT provides a repeatable and measurable process for financial institutions to assess their cybersecurity preparedness. It helps institutions identify their risks and determine their cybersecurity maturity1. The CAT is a bit of a monster for small or large teams. The Cybersecurity Assessment Tool has 533 questions for your current environment. How to interpret and answer some of these questions can get tough. Guardian can be your guide. Let us help manage the completion and keep it on track. Or if you want a little bit of guidance, bounce an idea off of someone, or a question here or there feel free to email me. I'm looking to build relationships to help community banking. Tandem has the best product for this in my opinion. It shows peer results, you can compare to the previous year and the reporting is great. I'm not going to push anyone towards a certain product. I'm here to be helpful and keeping it to spreadsheets or word doc is what you are happy with, we can get the mission accomplished no matter what tool you use.
- Authentication and Access Guidance: This guidance provides financial institutions with examples of effective authentication and access risk management principles and practices for customers, employees, and third parties accessing digital banking services and information systems2.
- Cybersecurity Resource Guide: The FFIEC’s Cybersecurity Resource Guide offers a range of resources to assist financial institutions in strengthening their resilience to cyber threats. The guide includes updated references and ransomware-specific resources to address the ongoing threat of ransomware incidents3.
Annual Due Diligence Requirements
Financial institutions are required to perform due diligence annually to ensure compliance with FFIEC regulations and to maintain robust cybersecurity practices. Key aspects of annual due diligence include:
- Risk Assessments: Conducting regular risk assessments is essential to identify potential vulnerabilities and threats. Financial institutions should evaluate their cybersecurity posture and update their risk management strategies accordingly. Do you need some help getting started or maturing your current assessments. We are a Conetrix Tandem partner and would be happy to help with getting Tandem up to date or working with your risk assessment processes. There is nothing wrong with using Excel or Word until you feel like you need a dedicated program. Tandem is excellent.
- Policy and Procedure Reviews: Institutions must review and update their cybersecurity policies and procedures annually. This includes ensuring that policies are aligned with the latest regulatory requirements and industry best practices. We can help, I mean it. If you want to improve or need to create your policies, I'm happy to work with your team and you. If you need technical or business process improvement to save money long term by being more efficient. Guardian is there for you. I know every policy the examiners will ask for and ones to help your institution in the long run. I promise there are some processes out there costing you money unless you are actively working on process improvement.
- Employee Training and Awareness: Annual training programs should be conducted to educate employees about cybersecurity threats and best practices. This helps in fostering a culture of security awareness within the organization. Guardian has managed Employee training and awareness and the reports to go along with it. Want to see who is completing your security awareness training and who isn't and find your high-risk security users? How about automating additional training for those specific users? Examiners are going to ask what you're doing and then provide evidence for how well you are managing everyone performing the awareness training. Let us help!
- Third-Party Vendor Management: Financial institutions must perform due diligence on third-party vendors to ensure they adhere to cybersecurity standards. This includes reviewing vendor contracts, conducting security assessments, and monitoring vendor performance. We can help with getting your Tandem vendor management up to date and accurate or work through your own processes. Either way we are product agnostic when it comes to teaming up with you to make life better at work.
- Incident Response Planning: Institutions should review and update their incident response plans annually. This ensures that they are prepared to respond effectively to cyber incidents and minimize potential damage. Contact Guardian if you would like to review our incident response tabletop exercise package.
- Compliance Audits: Regular compliance audits should be conducted to verify adherence to FFIEC regulations and identify areas for improvement. These audits help in maintaining accountability and ensuring continuous improvement in cybersecurity practices. Guardian is happy to do compliance audits or work with you to get a benchmark where you are currently at and help develop a 6-to-24-month plan to fill the gaps and we can even assist with incorporating all this information into your strategic plan for the board or IT Steering committee.
Adhering to FFIEC regulations and performing annual due diligence are critical for financial institutions to safeguard against cyber threats. By following and practicing the guidelines outlined in this article, institutions can enhance their cybersecurity posture and ensure compliance with regulatory requirements. Continuous improvement and vigilance are key to maintaining a secure and resilient financial environment. Guardian is happy to help with any of your due diligence responsibilities. I have 25 years' experience with implementing and completing these requirements. You don't have to do everything, we can manage, co-manage or train you or your team in creating or improving your current programs.
