“The days of Dan Hadaway’s spreadsheets are numbered.”
We were open to this reality very early on, because we had been asking ourselves many related questions for several years. Many of our Clients suggested we turn our spreadsheets into a database, but we knew we were weak in the “non-IT areas of Enterprise Risk Management (ERM).” We are not experts in BSA, Loan Risk, Market Risk, Business Continuity Planning, etc.
So the questions became, how do we approach ERM, given that we only know the IT side of risk assessing? How are we going to make sure our approach can plug into a bank’s overall enterprise risk management approach? How are we going to audit banks using ERM applications if we have no experience using them ourselves? Finally, how do we design audits using our Clients’ risk assessments, when they are no longer coming from spreadsheets?
So in November 2012, we began a search and selection process that took us through seven different ERM applications and ended up with our becoming a reseller of TRAC. Early on we investigated the independence issues surrounding our adopting an application and what we’ve determined is that, since we have to conduct a risk assessment as part of the audit, the only issue that will come out is that we will need to footnote our reports stating that we are resellers of TRAC, if our reports comment on the veracity of the Client’s risk management program (which they almost always will.)
In other words, we can remain independent as long our Clients (and report readers) are aware of the fact that we use TRAC. This is the same with our use of Nessus, MSBA, Nikto, MSAT, ophcrack, etc.
Meanwhile, we will be able to easily conduct a risk assessment for you, and show you how to integrate all of your risk measurement, response, and monitoring activities . . . . from business continuity to asset management to BSA to vendor management to drill-down product-based assessments. They’ve even got a customer risk assessment in this package. The benchmarking is by bank size, type of infrastructure, asset type, etc. Plus, they’ve got over 400 banks in their database (and growing!)
We’re very excited about the possibilities of helping our Clients streamline the entire IT Governance process. The fact that you’ll have one metrics system to apply to all of your risk assessments will make it easier for executives to see risk across the enterprise. Resource allocation will improve and be focused on the greatest risk mitigation. Compliance will be easier!
The seven alternatives were whittled down based on their ability to serve community based banks in Indiana and Ohio. We had some very unique requirements, including:
- Does the application address the minimum requirements of an Enterprise Risk Management Application?
- Does the application undergo a true, managed, system development life cycle that includes security testing?
- Does the provider already work with small, community-based banks?
- How large of a bank can this application scale to?
- Does the application exude an understanding of information security, it governance, and bank compliance best practices?
- Does the application facilitate an asset-based, multidisciplinary, metrics-oriented (with inherent and residual risk calculations) risk assessment process (or is it a glorified spreadsheet?)
- How well does the application facilitate vendor management, customer risk management, incident response, business impact analysis, and individual drill-down risk assessing on individual assets?
- How well does the application facilitate benchmarking with other similar-sized banks?
- Does the provider already have price points that are reasonable for a community-based bank?
- Does the application allow for modularity and updating?
- How customizable is the application?
- Does the application allow for benchmarking? Against community-based banks? By different categories? By asset?
- Will the provider allow Infotex to weigh in on the design changes and version priorities?
- Does the provider currently respond quickly to ideas and requests? Did (or will) the provider respond to an idea during the analysis portion of our process?
- Does the provider have a complete, sufficient due diligence packet?
- Does the provider demonstrate an understanding of win-win relationships?
- Is the provider willing to work with the Indiana Bankers Association and other associations, and provide marketing-free education?
The infotex staff is now working closely with the Secure Banking Systems staff to plan the rollout of this partnership. We will be training in December and January. If you are interested in learning more about enterprise risk management, we will be providing more information at our booth at the IT Security Conference, and have arranged for a series of webinars so you can learn more about Enterprise Risk Management in general, as well as the reasons we believe TRAC is a no-brainer for small community based banks to try!