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Don’t Mis-Interpret the Vendor Management Regs!

By Dan Hadaway | Sunday, September 14, 2014 - Leave a Comment

Heck, don’t misinterpret the regs period!


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“Ahem . . . . how about a little sanity please?”

An article shared on LinkedIn by my friend Kelli Schultz (of Digital Compliance) got me thinking: I’ll bet we’re all prone to mis-interpret various regulations on a regular basis.

The article, written by Paul Schaus of CCG Catalyst, is a must-read for anybody trying to manage vendor risk.  Even if you are not in the banking industry, this article can help us keep our senses as we develop procedures for vendor review and risk management.   You can find the article here, published by American Banker.

The article came at a great time for me, as I’m preparing for the 10/23/2014 Vendor Management Workshop at the Indiana Banker’s Association.   Though this will be a bank-oriented workshop, if you are not a banker you may find this to be a great eye-opener as to where your own vendor management program is going to end up a few years down the road.  I say this based on the fact that for the past 15 years banks have been the early adopters of Information Security Technologies.  We’re blazing the trail over here in the financial industry, and it’s not always pretty.

And that ugliness includes Vendor Management.

In his article . . . . . did I mention it was a “must-read?” . . . . . Schaus starts out proposing that some of us may be reacting a bit too strongly to the 2013 OCC Guidance on Third Party Management.  Schaus then suggests a couple of examples, including vendor size and a bank’s right to audit, and in his discussion he sheds light on some of the more prevalent myths we find in some interpretations of the guidance.

And, as I said, it got me thinking . . . . 

How do we auditors go about checking our own interpretations of various guidances, documents, rulings, etc?   I mean, my Clients count on us to check THEIR intepretation, but who do we have to check ours?

I’m glad that I’ve always tried to develop relationships with bank examiners and other regulators in various industries.  I’m thankful that for the past six years, because we offer our Managed Security Services, we are in the FFIEC TSP Examination Program.  It gives me great exposure to at least five examiners every other year, and during the examination it provides opportunities to discuss information security philosophies with the people who are in the best position to explain how regs are being interpreted.

And I have to say I’m very proud of the regular exhibitors at the Annual Information Security and Risk Management Conference put on by the Indiana Bankers Association and the Community Bankers Association of Ohio.  This conference is not only a great resource for bankers, but over half of the exhibitors are always IT Audit Firms.  I remember somebody commenting once, “I’ve never been to a conference where all the exhibitors sit and listen in on the talks like they do at this conference.”

And each year at least a half dozen of the speakers are usually from IT Audit Firms.

So now I’m looking forward to this year’s conference, scheduled for 11/19 and 11/20/2014.  I am coming to the show with a new-found perspective!  I hope to see you ALL there!


Original article by Paul Schaus.
Read the full story here.


This is a “Dan’s New Leaf” post.  Dan’s New Leaf is a fun blog attempting to inspire thought in the area of technology risk management.


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