Information Overload 2017
2017 – Ten Guidance Releases and the Solution . . .
A sidebar from our 2017 M-7 Article!
Another one of those Dan’s New Leaf Posts, meant to inspire thought about IT Governance . . . .
We felt our M-7 article should inventory the new guidance you’ll need to get your arms around in 2017. However, when we did this, the one trend about information overload was overloaded with information! Thus, this sidebar illustrates the compliance burden faced with in 2017. Remember, these ten documents are simply what’s already out there. We don’t know what’s coming in 2017.
- The Cybersecurity Assessment Tool – while this was released in 2015, “the time to pay the pauper” is coming due in 2017, especially if you’re an OCC regulated bank. An MRA for every case you’re not at baseline needs to be taken seriously.
- Management Booklet (part of IT Exam Handbook). Updated in 11/10/2015, this new guidance expands the previous tactics of Information Security into the more comprehensive strategy of IT Governance.
- Appendix J – Another 2015 guidance that is going to be supervised against rather closely. If you haven’t integrated the implications of this into your vendor management and business continuity programs, you should do so soon.
- CAT FAQ – October 2016 release . . . this is a handy frequently asked questions guidance about the Cybersecurity Assessment Tool. You can claim ignorance no more!
- Update to Information Security Booklet – On 09/09/16 the FFIEC updated the Information Security Booklet, seemingly abandoning all pretense that CAT statements were always in guidance. It clarifies things, and adds to your to-do list.
- Interbank Messaging – While not setting any new guidance itself, this June 2016 bulletin put everyone on notice that attacks against interbank networks and wholesale payment systems had been observed in the wild . . . and reminded banks that they should be using multiple layers of security, including addressing the risk of compromised credentials in their risk management process.
- Retail Payment Systems Booklet – This 147 page document was revised in April 2016 to include new guidance for electronic retail payment systems including remotely created checks, electronically created payment orders and automated clearing house transactions.
- Extortion Statement – The FFIEC issued this notice to financial institutions in November 2015, providing guidance on responding to cyber attacks involving extortion, such as ransomware, and how to avoid becoming a victim in the first place.
- Statement on Compromised Credentials – A warning to financial institutions that they should be reviewing their risk management practices and controls to prevent attacks using stolen account credentials.
- Statement on Malware – Coming at the same time as the statement on compromised credentials, this statement calls on institutions to review their risk mitigation plans in regards to malware.
Now, you may wonder, what is the solution to this problem?
“The bad news is time flies. The good news is you’re the pilot.”
― Michael Altshuler”
The only way we’re going to be able to handle these periodic gluts of new guidance, without investing in more people, is to manage our time better. It’s time to invest in time management training.
Original article by Dan Hadaway CRISC CISA CISM. Founder and Managing Partner, infotex
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