Excerpted from FFIEC Cybersecurity Assessment Tool, Inherent Risk Profile . The following resources can help management and directors of financial institutions understand supervisory expectations, increase awareness of cybersecurity risks, and assess and mitigate the risks facing their institutions. Watkins’ latest Excel workbook includes this functionality. FFIEC defines a compensating control as “A management, operational, and/or technical control (e.g., safeguard or countermeasure employed by an organization in lieu of a recommended security control in the low, moderate, or high baselines that provides equivalent or comparable protection for an information system. For suggestions regarding this site, Contact Us. If management determines that the institution�s maturity levels are not appropriate in relation to the inherent risk profile, management should consider reducing inherent risk or developing a strategy to improve the maturity levels. Step 1: Read Overview for Chief Executive Officers and Boards of Directors to gain insights on the benefits to institutions of using the Assessment, the roles of the CEO and Board of Directors, a high-level explanation of the Assessment, and how to support implementation of the Assessment. The FFIEC recently released a long-awaited update to the Cybersecurity Assessment Tool, and we think overall it is a relatively minor but useful evolution.But before we get into the details of what the update does address, it’s important to note that it did not address the ambiguity issues that plague the current assessment. These tools include the FFIEC Cybersecurity Assessment Tool, the National Institute of Standards and Technology Cybersecurity Framework, the Financial Services Sector Coordinating Council Cybersecurity Profile, and the Center for Internet Security Critical Security Controls. 1. piloted a cybersecurity examination work program (Cybersecurity Assessment) at over 500 community financial institutions to evaluate their preparedness to mitigate cyber risks. Independence and Staffing of Internal IT Audit, Audit Participation in Application Development, Acquisition, Conversions, and Testing, Independence of the External Auditor Providing Internal Audit Services, Third-Party Reviews of Technology Service Providers, Appendix C: Laws, Regulations, and Guidance, II Business Continuity Management Governance, II.A Board and Senior Management Responsibilities, III.A.1 Identification of Critical Business Functions, VII.I Third-Party Service Provider Testing, VII.J Testing for Core and Significant Firms, VII.K Post-Exercise and Post-Test Actions, International Organization for Standardization, Software Development Contracts and Licensing Agreements, Software Licenses and Copyright Violations, Documentation, Modification, Updates, and Conversion, Subcontracting and Multiple Vendor Relationships, Liquidity, Interest Rate, Price/Market Risks, Cost-Benefit Analysis and Risk Assessment, Oversight and Monitoring of Third Parties, Transaction Monitoring and Consumer Disclosures, I Governance of the Information Security Program, II Information Security Program Management, II.A.3 Supervision of Cybersecurity Risk and Resources, II.C.1 Policies, Standards, and Procedures, II.C.5 Inventory and Classification of Assets, II.C.10 Change Management Within the IT Environment, II.C.16 Customer Remote Access to Financial Services, II.C.20 Oversight of Third-Party Service Providers, II.C.21 Business Continuity Considerations, III.A Threat Identification and Assessment, III.C Incident Identification and Assessment, IV Information Security Program Effectiveness, I.B.6 Planning IT Operations and Investment, III.C.1 Policies, Standards, and Procedures, III.C.5 Software Development and Acquisition, III.D.6 Quality Assurance and Quality Control, Risk Mitigation and Control Implementation, Information Distribution and Transmission, Appendix D: Advanced Data Storage Solutions, Key Service Level Agreements and Contract Provisions, General Control Environment of the Service Provider, Potential Changes due to the External Environment, Outsourcing the Business Continuity Function, Appendix B: Laws, Regulations, and Guidance, Appendix C: Foreign-Based Third-Party Service Providers, Appendix D: Managed Security Service Providers, Payment Instruments, Clearing, and Settlement, Online Person-to-person (P2P), Account-to-Account (A2A) Payments and Electronic Cash, Contactless Payment Cards, Proximity Payments and Other Devices, Biometrics for Payment Initiation and Authentication, Retail Payment Instrument Specific Risk Management Controls, Appendix C: Schematic of Retail Payments Access Channels & Payments Method, Appendix D: Laws, Regulations, and Guidance, Supervision of Technology Service Providers, C. Holding Company and Non-Bank Subsidiary of the Holding Company, E. Independent TSPs, Including Those in the Multi-Regional Data Processing Servicers Program, Shared Application Software Review Program, Uniform Rating System for Information Technology, Fedwire and Clearing House Interbank Payments System (CHIPS), Other Clearinghouse, Settlement, and Messaging Systems, Society for Worldwide Interbank Financial Telecommunication (SWIFT), National Securities Clearing Corporation (NSCC), Internally Developed and Off-The-Shelf Funds Transfer Systems, Computer and Network Operations Supporting Funds Transfer, Wholesale Payment Systems Risk Management, Tier I Examination Objectives and Procedures, Tier II Examination Objectives and Procedures, Appendix C: Laws, Regulations and Guidance, Appendix D: Legal Framework for Interbank Payment Systems, Appendix E: Federal Reserve Board Payment System Risk Policy: Daylight Overdrafts, Account Balancing Monitoring System (ABMS), Bank Identification Number/Interbank Card Company (BIN/ICA), Clearing House Interbank Payment Systems (CHIPS), Domain Name System security extensions (DNSSEC), Due diligence for service provider selection, Financial Services Information Sharing and Analysis Center (FS-ISAC), National Institute of Standards and Technology (NIST), Personally identifiable financial information, U.S. Computer Emergency Readiness Team (US-CERT). Credit unions should review the Tool and determine whether or not there is Controls, Control Objectives for Information Technologies (COBIT), Federal Financial Institutions Examination Council Cybersecurity Assessment Tool (FFIEC CAT), Financial Services Sector Coordinating Council (FSSCC) Cybersecurity Profile, International Organization for Standardization (ISO), National Institute of Standards and Step 5: Interpret and Analyze Assessment Results to understand whether the institution�s inherent risk profile is appropriate in relation to its cybersecurity maturity and whether specific areas are not aligned. Additional response options included in the assessment … The FFIEC’s tool measures risk levels across several categories, including delivery channels, connection types, external threats, and organizational characteristics. Home » Glossary » C » Compensating control. It helps assess an institution’s inherent cyber risk profile and its cybersecurity … The Information Technology Examination Handbook InfoBase concept was developed by the Task Force on Examiner Education to provide field examiners in financial institution regulatory agencies with a quick source of introductory training and basic information. FFIEC members developed the Assessment to help institutions’ management identify their risks and determine their cybersecurity preparedness. The FFIEC risk assessment tool allows your financial institution to be more strategic in its allocation of resources to IT defenses by assigning priority to the most at risk areas. Last Modified: 04/15/2020 11:10 AM, EGRPRA (Economic Growth and Regulatory An example of compensating controls would be a review of activity log s for applications that do not allow proper segregation of duties. The FFIEC released a document earlier this month covering some of the most frequently asked questions surrounding the Cybersecurity Assessment Tool (CAT), and it's … The FFIEC CAT (Cybersecurity Assessment Tool) provides financial institutions with a repeatable and measurable process that enterprises can use to gauge cybersecurity preparedness. In light of the increasing volume and sophistication of cyber threats, the Federal Financial Institutions Examination Council (FFIEC) developed the Cybersecurity Assessment Tool (Assessment) to help institutions identify their risks and determine their cybersecurity preparedness. FFIEC Cybersecurity Assessment Tool Frequently Asked Questions (opens new window) The NCUA expects credit unions to have the appropriate procedures in place to anticipate, identify, and mitigate cybersecurity risks.Specific expectations can be found in the body and appendices of Part 748 of NCUA regulations (opens new window) as well as the FFIEC IT Examination Handbooks. A federal agency may not conduct or sponsor, and an organization (or person) is not required to respond to, a collection of information unless it displays a currently valid OMB control number. While the press release lists the FFIEC CAT, NIST Cybersecurity Profile, Center for Internet Security Controls, and FSSCC Cybersecurity Profile as references to "support institutions in their self-assessment activities," the press release reiterates that "the FFIEC does not endorse any particular tool" and the "tools are not examination programs." Questions from vendor management to mitigating controls covered in the new document. Refer to the User's Guide for additional explanation of Steps 3, 4, and 5. This event focuses on describing the effective components of the FFIEC Cybersecurity Assessment Tool and their usage. The Assessment provides a repeatable and measurable process for financial institutions to measure their cybersecurity preparedness over time. Step 2: Read the User's Guide (Update May 2017) to understand all of the different aspects of the Assessment, how the inherent risk profile and cybersecurity maturity relate, and the process for conducting the Assessment. More importantly, you can use the results of the survey to prioritize cybersecurity initiatives and controls going forward. )”In practice, this update will allow financial institutions to achieve higher … This version also includes updates as suggested by those using the workbook. Step 4: Complete Part 2: Cybersecurity Maturity of the Cybersecurity Assessment Tool (Update May 2017) to determine the institution�s cybersecurity maturity levels across each of the five domains. You will learn how to use of this structured approach to evaluation of your needs provided by the banking regulators. In 2017 the FFIEC updated their tool to include the option “Yes, with compensating controls” when answering the risk maturity, declarative statements. The Assessment provides a repeatable and measurable process that financial institutions’ management may use to measure their cybersecurity preparedness over time. You may remember that in 2014, FFIEC stated that they wanted financial institutions to adopt the NIST Cybersecurity Framework. If all of these FFIEC statements are true, that makes it easier to answer several questions in NIST CSF about the maturity of several inventory practices involving hardware, software, services, and data assets. 1. 2. (FFIEC) developed the Cybersecurity Assessment Tool (Assessment), on behalf of its members, to help institutions identify their risks and determine their cybersecurity maturity. The update to the cybersecurity maturity section of the tool allows institutions to select “Yes with Compensating Controls”, meaning that an institution has implemented a control or controls that protect an information system in a manner that is comparable or equivalent to a recommended security control within a declarative statement. On June 30, 2015, the Federal Financial Institution Examinations ouncil (“FFIEC”) published a Cybersecurity Assessment Tool (“Assessment Tool,” “Tool” or “AT”) to provide all financial institutions with a repeatable and measureable process to inform management of their institution’s risks (Inherent Risk Profile) and cybersecurity Cybersecurity is an area of growing concern for financial institutions, especially in the face of recent high-profile data breaches. Paperwork Reduction Act � OMB Control No. The FFIEC Cybersecurity Assessment Tool (CAT) is a diagnostic test that helps institutions identify their risk level and determine the maturity of their cybersecurity programs. The content of the Assessment is consistent with the principles of the FFIEC Information Technology Examination Handbook (IT Handbook) In June of this year, the Federal Financial Institutions Examination Council (FFIEC) released its Cybersecurity Self Assessment Tool (CAT) to help institutions determine their risks and evaluate their preparedness. In addition to the �Overview for Chief Executive Officers and Boards of Directors�, the FFIEC has released the following documents to assist institutions with the Assessment. Compensating control s are controls that adjust for weaknesses within the system or process. 3. The Federal Financial Institutions Examination Council (FFIEC) has updated the Cybersecurity Assessment Tool to reflect changes to the FFIEC IT Examination Handbook.. Incident Analysis: FFIEC members will enhance its processes for gathering, analyzing and sharing information with each other during cyber incidents. The Assessment incorporates cybersecurity-related principles from the FFIEC Information Technology (IT) Examination Handbook and regulatory guidance, and concepts from other industry standards, including the National Institute of Standards and Technology (NIST) Cybersecurity Framework. •Compensating control - A management, operational, and/or technical control (e.g., safeguard or countermeasure) employed by an organization in lieu of a recommended security control in the low, moderate, or high baselines that provides equivalent or comparable protection for … Overview for Chief Executive Officers and Boards of Directors (PDF), Cybersecurity Assessment Tool (PDF) (Update May 2017), Print all documents at once (PDF) (Update May 2017), FFIEC Cybersecurity Assessment Tool Presentation View Slides (PDF) | View Video. The FFIEC Cybersecurity Assessment Tool is a good start toward performing security assessments, but expect to see changes in the next version that adapt it to becoming a more useful tool. Compensating control Information Security A management, operational, and/or technical control (e.g., safeguard or countermeasure) employed by an organization in lieu of a recommended security control in the low, moderate, or high baselines that provides equivalent or comparable protection for an … Summary On June 30, 2015, the Federal Financial Institutions Examination Council (FFIEC), 1 on behalf of its members, issued a Cybersecurity Assessment Tool (Assessment) that financial institutions may use to evaluate their risks and cybersecurity preparedness. These tools include the FFIEC Cybersecurity Assessment Tool, the National Institute of Standards and Technology Cybersecurity Framework, the Financial Services Sector Coordinating Council Cybersecurity Profile, and the Center for Internet Security Critical Security Controls. 2. 1557-0328; Expiration date: August 31, 2019 UPDATE: Safe Systems just released their Enhanced CyberSecurity Assessment Toolkit (ECAT) – This enhanced version of the FFIEC toolkit addresses the biggest drawback of the tool; the ability to collect, summarize, and report your risk and control maturity levels. The Information Technology Examination Handbook InfoBase concept was developed by the Task Force on Examiner Education to provide field examiners in financial institution regulatory agencies with a quick source of introductory training and basic information. The framework has two focuses. NIST Cybersecurity Framework FFIEC Cybersecurity Assessment Tool A clear understanding of the organization’s business drivers and security considerations specific to use of informational technology and industrial control systems. Maintained by the FFIEC. However, because of the advanced and increasing trend of cyber threats to … Cybersecurity Self-Assessment Tool: FFIEC issued the self-assessment tool in June 2015. The most significant change to the CAT is the addition of a choice to answer cybersecurity maturity declarative statements with “Yes With Compensating Controls” (Y (C)), as opposed to the previous “Yes” or “No” (Y/N) option. Step 3: Complete Part 1: Inherent Risk Profile of the Cybersecurity Assessment Tool (Update May 2017) to understand how each activity, service, and product contribute to the institution�s inherent risk and determine the institution�s overall inherent risk profile and whether a specific category poses additional risk. An article review. The assessment updates reflect changes to the FFIEC's Information Security and Management booklets. Cybersecurity Assessment Tool In light of the increasing volume and sophistication of cyber threats, the Federal Financial Institutions Examination Council (FFIEC) developed the Cybersecurity Assessment Tool (Assessment) to help institutions identify their risks and determine their cybersecurity preparedness. Paperwork Reduction Act of 1996), Appendix A: Mapping Baseline Statements to the FFIEC IT Handbook, Appendix B: Mapping to NIST Cybersecurity Framework, Read Overview for Chief Executive Officers and Boards of Directors, Complete Part 1: Inherent Risk Profile of the Cybersecurity Assessment Tool, Complete Part 2: Cybersecurity Maturity of the Cybersecurity Assessment Tool, Appendix A: Mapping Baseline Statements to FFIEC IT Handbook (Update May 2017). CU*Answers agrees with CUNA’s review that the Tool has value, but is likely to take far longer than the 80 hours estimated by the FFIEC, and there are significant problems with the Tool itself. Written by Shari R. Pogach, Regulatory Paralegal. Crisis Management: FFIEC will align, update and test emergency protocols to respond to system-wide cyber FFIEC Cybersecurity Assessment Tool should be voluntary for credit unions. A management, operational, and/or technical control (e.g., safeguard or countermeasure) employed by an organization in lieu of a recommended security control in the low, moderate, or high baselines that provides equivalent or comparable protection for an information system. We cover how to evaluate and discuss cybersecurity risk and the maturity of existing controls. During the summer of 2014, Federal Financial Institutions Examination Council (FFIEC) members. 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