Back to Blog

Why Management’s FDICIA Attestation Must Include an Understanding of Access Reviews

By Zach Duke

December 17, 2024

Get notified on new insights from Finosec now!

Be the first to know about new Finosec blogs to grow your knowledge of the cybersecurity governance industry today!

For financial institutions subject to FDICIA, the Federal Deposit Insurance Corporation Improvement Act, the annual management attestation is a critical declaration of compliance. It signifies that the institution’s internal controls over financial reporting (ICFR) are effective. One key control to validate is how user access reviews are performed.

Banking system access reports often involve massive, unstructured text reports that can span hundreds—or even thousands—of pages. Without a structured process for managing and interpreting these reports, institutions risk gaps in their internal control framework and potential non-compliance.

The Connection Between Access Reviews and FDICIA Attestation

The management attestation requires leaders to assert that the institution’s ICFR is operating effectively. A cornerstone of this effectiveness is ensuring that access to systems that impact financial reporting are properly controlled.

Key considerations include:

  1. Are Access Reviews Performed Effectively?
    • Institutions must confirm that access reviews are not just performed but are thorough and actionable.
    • Reviews should align with organizational policies, including frequency based on the criticality of the system, review of privileged access, and independence of the review.  
  2. Can Management Interpret Review Results?
    • Massive, unstructured reports often make it difficult for auditing let alone executive management reporting, leading to challenges when trying to spot issues.
    • Without tools to distill these reports into actionable insights, critical risks may go unnoticed.
  3. Are Access Review Processes Documented?
    • Auditors will expect clear evidence of how access reviews are conducted, the independence included, how the results are assessed, and how changes are implemented.

The Challenges of Unstructured Access Review Reports

Unstructured reports often present the following challenges:

  • Volume of Data: Hundreds of pages of raw data can be overwhelming to sift through manually.
  • Lack of Context: Reports may list permissions or codes without explaining their relevance or risk level.
  • Inefficiency: Extracting actionable insights from unstructured reports can be time-consuming and prone to error.

Three Questions to Ask Before Finalizing Your Management Attestation

To ensure that access reviews are effectively incorporated into the FDICIA attestation, ask the following:

  1. How Complicated Is the Access Review Process?
    • Are the reports structured and easy to interpret, or do they require extensive manual effort?
  2. Are Privileged Permissions Highlighted in Reports?
    • Do reports clearly identify high-risk accounts and permissions?
    • Ensure these permissions are reviewed with extra scrutiny.
  3. How Are Changes Highlighted Since the Last Review?
    • Can reports easily identify access changes made since the last review?
    • Highlighting deltas helps detect anomalies quickly.
  4. Have all terminated employees been removed from systems?
    • Integrating termination governance to access reviews addresses one of the biggest risks with access management and a common audit finding.
  5. Is there independence in the access review?
    • Community banks often struggle with independence during the access reviews as the system owner may be the best person to review the access reports; however, segmentation of duties and independence are a key part of the need for performing access reviews based on FFIEC Guidance.

If all of this sounds complicated and complex, the team at Finosec is here to help. We’re committed to creating resources to guide you on your compliance journey, and our experts are ready to discuss how Governance360 can streamline your access reviews and strengthen your FDICIA compliance efforts.

More from Finosec

Introducing Fin-Atics: A Thankful Launch of Our Customer Referral Campaign

Introducing Fin-Atics: A Thankful Launch of Our Customer Referral Campaign

During Thanksgiving, it’s the perfect time to reflect on gratitude—both personally and professionally. At Finosec, our commitment is grounded in one key principle: the customer is the reason why we’re in business. This belief has been instilled in me since childhood, thanks to the lessons of my father, who not only shaped my views on business but also inspired me to carry these values into my leadership today.

Mastering Access Management: Best Practices for Effective User Access Reviews

Mastering Access Management: Best Practices for Effective User Access Reviews

Access management is a critical component of cybersecurity and compliance, especially for financial institutions where security expectations are paramount. The challenges surrounding permissions management, particularly during user access reviews, are increasing due to regulatory expectations and the complexity of banking applications. In this blog post, we’ll explore the regulatory expectations, common exam findings, and best practices that can help your organization manage user access effectively while adhering to the principle of least privilege – limiting user access to only the resources necessary to perform their job functions.

The Critical Link Between Third-Party Risk Management (TPRM) and Access Management

The Critical Link Between Third-Party Risk Management (TPRM) and Access Management

As highlighted in a recent article from the Federal Reserve, managing third-party relationships and the access associated with those relationships is a critical component of Third-Party Risk Management (TPRM). The associated access third party vendors have to banking systems is known as Access Management and is foundational for mitigating risks associated with third-party relationships. Access Management may be easy to overlook because it does not always reside with the same person or team as TPRM; making it difficult to provide critical oversight.

With increased regulatory focus, how should institutions be thinking of Access Management? Here are five steps your institution can take today to strengthen your third-party governance.

The Critical Foundation of Managing Access to Banking Systems

The Critical Foundation of Managing Access to Banking Systems

Managing access to banking systems has become increasingly complex as financial institutions navigate legacy reporting systems, API access, and cloud solutions. These challenges, along with the risks posed by unmanaged systems, emphasize the need for maintaining a...

Talk To An Expert Now
Talk To An Expert Now 770.268.2765