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.
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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
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.
FFIEC Authentication Guidance: Are You Meeting the Expectation?
The FFIEC has updated their expectations for access management with the Authentication and Access to Financial Institution Services and Systems Guidance. This guidance expands beyond traditional customer authentication and places a significant emphasis on...
Preparing for Your Next Exam: Ensuring Identity Access Management Meets Expectations
Preparing for your next examination can feel overwhelming as the regulatory expectations continue to expand. As you gear up for your next regulatory examination (or audit), it is crucial to align with the expectations outlined in the Federal Financial Institutions...
Challenges of Manual User Access Reviews in Community Financial Institutions
When I first entered the banking world, user access reviews were much more straightforward. Spreadsheets were used to capture the basics of who had network and core application access. There was a page in each employee’s file listing the keys and codes they had, and...
Why You Need to Know Every System for Every Employee
Are you confident that your bank has clear and thorough visibility to every employee’s physical and digital access to systems? If you’re like most banks we work with, the answer to this question is “no”. There are many challenges that make tracking employee access...
The Hidden Risks of Shadow IT: Why Community Banks Need a Detailed System Inventory
In the world of community banking, the landscape of information security and cyber risk management has dramatically evolved. Gone are the days when all servers were in-house, and every application installation involved the IT department. Today, it’s easier than ever for a Compliance Officer to sign off on a new software tool to manage Reg DD challenges or for a Loan Officer to adopt a cloud solution to improve customer acceptance rates.
Integrating FFIEC Authentication Guidance: A Blueprint for Your Next Exam With Insights from Recent Regulatory Actions
The Federal Financial Institutions Examination Council (FFIEC) Authentication Guidance update in August 2021 has marked a significant step towards enhancing authentication and security access measures within financial institutions. This update expanded upon previous handbooks from 2005 and 2011, emphasizing a broader scope that now includes employees, third-party vendors, and system-to-system communications via APIs.