Blog: Financial Institutions

What is the FSSCC Cybersecurity Profile?

The FSSCC Cybersecurity Profile was published on October 25, 2018 by the Financial Services Sector Coordinating Council (FSSCC). The FSSCC is a private entity comprised of 70 members from financial services organizations. Their cybersecurity profile has multiple tiers, which allow users to answer a scalable set of questions. This scaling is designed to provide an expedited assessment of the user's organization's cybersecurity preparedness.

The FSSCC has publicized their Cybersecurity Profile as a resource, designed to simplify the regulatory burden placed on financial institutions. According to the FSSCC's Benefits to Financial Institutions section of their website, the tool offers a "73% reduction for community institution assessment questions" when compared to the FFIEC CAT.

In addition to the tool's claims of efficiency, the tool's development is largely credited to organizations familiar to the financial services industry. The Press Release includes names such as the American Bankers Association, Bank Policy Institute, the Institute of International Bankers, and more.

Beyond this, the FSSCC has made multiple appeals to the Cybersecurity Profile's usefulness in regulatory examinations, going so far as to claim, "The numerous and substantial benefits [of using the FSSCC Cybersecurity Profile] to the financial services sector are: […] Supports tailored supervision, examinations, and collaboration among state, federal, and international supervisors," per the FSSCC Overview and Users Guide.

What is the FFIEC Cybersecurity Assessment Tool?

The FFIEC Cybersecurity Assessment Tool (CAT) was initially published on June 30, 2015, and updated May 31, 2017. The CAT was designed by the Federal Financial Institutions Examination Council (FFIEC), a formal interagency body, comprised of members from the FRB, FDIC, NCUA, OCC, CFPB, and SLC. The CAT is standardized, which allows users to answer a specific set of questions, designed to provide a thorough assessment of their organization's cybersecurity preparedness.

The FFIEC CAT includes 494 cybersecurity maturity statements, which has resulted in some complaints. However, it is not only designed to provide a detailed assessment of a financial institution's current state of cybersecurity preparedness, it also enables targeted and long-term planning for growth and improvement.

With regard to examinations:

• The FDIC continues to heavily rely on the InTREx Work Program. While InTREx does state financial institutions are not required to use the FFIEC CAT to assess cybersecurity preparedness, the program also states FDIC examiners will reference the CAT's Appendix A when performing examinations.

• The NCUA is currently implementing the Automated Cybersecurity Examination Tool (ACET). The ACET is based on the FFIEC CAT, with a document request list to help credit unions understand, gather, and organize the documents needed for the examination. Read our blog on FAQs about the ACET

• In their Spring 2018 Semiannual Risk Perspective, the OCC announced they had "implemented the Federal Financial Institutions Examination Council (FFIEC) Cybersecurity Assessment Tool (CAT) into its examination process." In addition, an OCC representative at the 2019 CoNetrix KEYS Conference Examiner Panel indicated the OCC is piloting their own segmented version of the FFIEC CAT, to be fully completed on a three-year cycle.

• The FRB's supervisory letter about the tool, SR 15-9, indicated the CAT's planned use in examinations, and the FRB was a contributor in the May 2017 update of the tool, per their 2017 Annual Report. Additionally, a list of Information Technology Guidance was published, including the FFIEC CAT as a "Policy Letter."

Will the FSSCC Cybersecurity Profile Replace the FFIEC Cybersecurity Assessment Tool?

While the FSSCC Cybersecurity profile has fewer questions, and the FSSCC has expressed interest in seeing the tool used during regulatory examinations, the federal banking agencies have not yet expressed the same interest.

In addition, while completing the FFIEC CAT is not required, four years into the CAT's implementation, examiners are now familiar with the tool and the agencies continue to supplement and reference the CAT in their own examination programs. In light of this, using the CAT to assess cybersecurity preparedness could help expedite the examination process, as the tool may be used during an exam.

At this point in time, it is not clear what the future holds for the FSSCC Cybersecurity Profile. Due to the thorough nature and widespread adoption of the FFIEC CAT, it is difficult to imagine the CAT will be replaced by any tool in the foreseeable future.

Does CoNetrix have anything that can help with assessing cybersecurity preparedness?

Yes. The Tandem Cybersecurity module took the FFIEC CAT PDF content and streamlined it into an easy-to-use web-based application. With email reminders, charts and graphs, presentation documents, optional peer comparison, and tools for the NCUA's ACET, you can put the FFIEC CAT to work for you. Get started for free with Tandem Cybersecurity.


Microsoft has been emphasizing Office 365 subscription services since the public introduction in 2011. As a result, the popularity of these services has grown to over 155 million active users as of October 2018, and is gaining new users at over 3 million seats per month. With this growth, on-going marketing, and the increasing acceptance of public cloud services, many businesses and financial institutions are starting to look at Office 365.

In this article, we will highlight several pros and cons of Office 365 you should consider to determine if it's right for your business.

Office 365 encompasses several different products and services, but in this article, we will address these services in two primary areas: user applications and back-end services.

Office 365 User Applications

As the name implies, most Office 365 subscription plans include Microsoft Office applications like Word and Excel running on Windows, macOS, and portable devices running iOS and Android. Applications are also available through a web browser but most customers are interested in Office 365 applications as a possible replacement for traditional Office licensing.

What are the primary differences between Office 365 and traditional on-premise Office applications?
  • Office 365 is an annual subscription per user or seat. Each user is entitled to run the Office 365 applications on up to 5 devices for the term of the subscription. As long as you continue to pay the annual subscription you are covered for the Office applications included in your plan.
  • Office applications through Office 365 are designed to be downloaded from the O365 portal. There is no license key to determine if you have a valid license. After installation the applications routinely "check in" to the O365 portal to ensure there is an active account. Because of this check-in process IT administrations must use a specific procedure for mass deployment of O365 applications. Additionally, installation on multi-user servers like Remote Desktop Services and Citrix requires a new approach.
  • Office 365 applications are designed to install features and security updates directly from Microsoft when they are released. Legacy patch management solutions like Windows Server Update Services (WSUS) and 3rd party solutions will not work with O365. This can create a challenge for regulated customers who are required to report on patch status. Scanning tools used by auditors to determine patch levels will need the ability to recognize the differences between O365 and traditional Office applications. The O365 update process could also create an issue for Office-integrated applications if a hotfix is released that affects the compatibility of those applications, as there will be no option to block that update from being installed.
  • Office 365 applications utilize a feature called Click to Run. This feature, which was originally introduced with Office 2016, provides a streaming method for installing features and patches for Office 365 and Office 2019 applications. Our experience is that Click to Run can use a significant amount of bandwidth if you are installing Office applications or large updates on multiple systems simultaneously.
Is licensing through Office 365 less expensive than traditional licensing?

For most customers the biggest question is: "Is licensing through Office 365 less expensive than traditional licensing?" The answer is "It depends!" Office 365 licensing could be financially attractive if:

  • Your business always updates to the latest release of Office.
  • You want the flexibility of per user licensing.
  • You want to take advantage of the licensing of up to 5 devices for multiple systems, mobile devices, home use, etc.
  • You need a simplified update process that works anywhere the PC has Internet connectivity.
  • You need to use the browser-based applications for a specific function or employee role.
  • You plan to implement one of the Office 365 back-end services.

Office 365 Back-End Services

Microsoft provides several cloud server applications through Office 365 including Exchange Online (email), Skype for Business Online (voice and messaging), SharePoint Online (web collaboration), and OneDrive (file storage and sharing). These back-end services can be implemented individually, or as part of a bundle with or without the Office applications depending on the plan. However Exchange Online vs. Exchange on-premise is receiving the most attention from our customers.

What should I look for when performing due diligence?

The security and compliance of back-end Office 365 services is not significantly different than any other cloud-based application or service. The areas that should be researched include:

  • External audit attestation – SSAE 18 or similar
  • Data location residency – production and failover scenarios
  • Data privacy policies - including encryption in transit and at rest
  • Contracts and licensing agreements
  • Intellectual property rights
  • Service Level Agreements – service availability, capacity monitoring, response time, and monetary remediation
  • Disaster recovery and data backup
  • Termination of service
  • Technical support – support hours, support ticket process, response time, location of support personnel
A few more things you should consider.

As a public cloud service Office 365 has several challenges that need specific attention:

  • The business plans listed on the primary pricing pages may include applications or services that you don't need. All of the various features can be confusing and it's easy to pick the plan that is close enough without realizing exactly what's included and paying for services you will never use.
  • Most of the back-end O365 services can integrate with an on-premise Active Directory environment to simplify the management of user accounts and passwords. This provides a "single sign-on" experience for the user with one username and password for both local and O365 logins. Microsoft has several options for this integration but there are significant security implications for each option that should be reviewed very carefully.
  • Microsoft has published several technical architecture documents on how to have the best experience with Office 365. This is especially important for larger deployments of 100+ employees, or customers with multiple physical locations. One of the notable recommendations is to have an Internet connection at each location with a next-generation firewall (NGFW) that can optimize Internet traffic for O365 applications. Redundant Internet connections are also strongly recommended to ensure consistent connectivity.
  • The default capabilities for email filtering, encryption, and compliance journaling in Exchange Online may not provide the same level of functionality as other add-on products you may be currently using. Many vendors now provide O365-integrated versions of these solutions, but there will be additional costs that should be included in the total.
  • Microsoft OneDrive is enabled by default on most Office 365 plans. Similar to other public file sharing solutions like Dropbox, Box, and Google Drive, the use of OneDrive should be evaluated very carefully to ensure that customer confidential data is not at risk.
  • Several other vendors provide Office 365 add-on products that provide additional functionality which may be useful for some businesses. Netwrix Auditor for Office 365 can provide logging and reporting for security events in your O365 environment. Veeam Backup for Office 365 can create an independent backup of your data to ensure it will always be available. Cloud Access Security Brokers (CASB) such as Fortinet FortiCASB and Cisco Cloudlock can provide an additional layer of security between your users and cloud services such as O365.

It is certainly a challenge to research and evaluate cloud solutions like Office 365. Financial institutions and other regulated businesses with high-security requirements have to take a thorough look at the pros and cons of any cloud solution to determine if it's the best fit for them.

CoNetrix Aspire has been providing private cloud solutions for businesses and financial institutions since 2007. Many of the potential security and compliance issues with the public cloud are more easily addressed in a private cloud environment when the solution can be customized for each business.

However, the combination of Office application licensing with back-end services like Exchange Online can be a good solution for some businesses. The key is to understand all of the issues related to Office 365 so you can make an informed decision.

Contact CoNetrix Technology at if you want more information about the differences between Aspire private cloud hosting and Office 365.



If you are a credit union, you should expect to see the ACET during your next IT examination. The NCUA began piloting this new examination tool in 2018 with larger credit unions, but we anticipate it will be used in most credit union examinations in 2019. As you prepare for the ACET, here is a list of frequently asked questions for you to review.

What is the difference between the CAT and the ACET?

While the ACET mirrors the CAT (the FFIEC's Cybersecurity Assessment Tool) in content, ACET provides additional content, features, and details to help credit unions and the NCUA examine and benchmark the industry's cybersecurity preparedness. To learn more about specific differences, read our in-depth post on the differences between the NCUA ACET and the FFIEC CAT.

Does the ACET replace the risk assessment requirement per GLBA?

No. While ACET should be considered complementary to information security risk assessment(s) as outlined in the Interagency Guidelines Establishing Information Security Standards per GLBA, it does not replace this requirement. 

Will NCUA IT Examinations be limited to ACET?

No. The NCUA indicates they will use the ACET during upcoming IT exams, and it will be in addition to risk-focused IT examinations.

Where do I get a copy of the ACET spreadsheet?

At the time of this post, the ACET is not available from the NCUA website. Per Supervisory Letter 17-CU-09, the NCUA stated they will "continue to test and refine the ACET through 2018," but you can download version 032618 of the ACET here. In addition, credit unions should receive the current version of the ACET prior to an IT examination. When the ACET is completed as part of the examination process, examiners will leave the completed ACET with the credit union, and discuss the results and any discrepancies with management.

Are credit unions required to complete the ACET?

No, the ACET is not required, but it is recommended. When the NCUA does an examination using the ACET, they will ask if the credit union has completed the ACET. If the credit union has not, the examiner will complete the ACET using the provided material from the exam request list. While this will not be considered a negative for the credit union, credit unions should complete the ACET ahead of time so they can have more meaningful discussions during the exam.

How can Tandem help my credit union with ACET?

Tandem offers an online tool to help financial institutions complete the FFIEC Cybersecurity Assessment Tool and the NCUA Automated Cybersecurity Examination Tool. The features allow credit unions to complete the assessment through Tandem and download the results in the ACET spreadsheet format. The Tandem online software comes in both a free and paid version. Join more than 1,000 other financial institutions and sign up for the free Tandem Cybersecurity Assessment Tool today by visiting 




CoNetrix developed the online software tool highlighted in the video help financial institutions such as banks, credit unions, mortgage companies and trust companies complete and report on the FFIEC Cybersecurity Assessment Tool. The Tandem Cybersecurity module is available in three versions: Free, Pro, and Pro+. 

Additionally, CoNetrix has updated the tool to include the additional ACET features and to allow Credit Unions to complete the assessment through Tandem and download the results in the ACET spreadsheet format.

Join more than 1,000 other financial institutions and sign up for the free Tandem Cybersecurity Assessment Tool today by visiting


In 2018, the NCUA began piloting the use of the Automated Cybersecurity Examination Tool (ACET) based on the FFIEC's Cybersecurity Assessment Tool (CAT) to review credit unions.  While the ACET mirrors the CAT in content, ACET provides additional features and details to help credit unions and the NCUA examine and benchmark the industry's cybersecurity preparedness. 

What are the additional features of the ACET as compared to CAT?  Let's take a look…

ACET is a spreadsheet

While the FFIEC Cybersecurity Assessment Tool (CAT) was called a tool, it was released in the form of a PDF download.  This forced financial institutions to complete the tool manually on paper, to develop their own mechanism to electronically complete the assessment, or to use third-party software such as Tandem to complete the assessment.  The ACET was released by the NCUA as a spreadsheet, partly, to provide credit unions a functional option for completing the CAT.

ACET includes a dashboard

The first sheet in the ACET spreadsheet is a dashboard.  The dashboard provides summary information of the credit union, a completion status for the inherent risk profile and cybersecurity maturity, and inherent risk levels.  The dashboard is helpful to let the credit union and their examiner see the completion status of the assessment. 

ACET has an Admin sheet for NCUA examination use

ACET was primarily designed to be used during NCUA examinations; therefore, the NCUA included an Admin sheet to be used by NCUA examiners.  This sheet is primarily used to calculate and track review hours used during the examination process.

ACET contains a document request list

Since ACET is used as an examination tool, or work program, a document request list was added.  The current version (v032618) of the ACET does not have a hyperlink from each document request to any inherent risk questions or maturity statements. However, validation text added to these statements, in many cases, does reference back to the requested items.

ACET adds validation text to inherent risk statements

Answers to the inherent risk profile statements help institutions determine their overall cybersecurity inherent risk.  ACET expanded these statements to include "Validation Approaches" for each inherent risk statement.  The validation approaches language describes what an institution or examiner should review to answer, or validate the answer to, an inherent risk statement.  In many cases, these validation approaches reference back to documents you can review from the document request list.

ACET summarizes maturity in a Maturity Details sheet

The ACET includes a sheet called "Mat. Details." This table provides a summary of the institution's maturity.  Percentages of "Yes" answers are displayed by Component for each maturity level.  This view provides a snapshot of the intuition's cybersecurity maturity across all of the Components.

ACET provides additional reporting fields for declarative statements

The ACET includes additional columns to help institutions document evidence or additional information related to each cybersecurity maturity declarative statement in the "Domain" sheets.  The first additional column, Comment [Required for Yes(c)], was added for credit unions to have a place to explain the "Yes with compensating controls" answer. Two additional columns, Reviewed and Suggested Edits, were added to help examiners when reviewing the ACET.

ACET incorporates a guide with additional commentary and mappings

The ACET includes a sheet named "Guide" with additional commentary and mappings to help an institution or examiner understand and answer the cybersecurity maturity declarative statements.  The additional columns include:

  • Comment: commentary with additional details describing what is expected from the declarative statement and what value the control has on cybersecurity.
  • Examination Approaches: describes what an institution or examiner should review to answer or validate the answer to a declarative statement.
  • Baseline Mapping: mapping declarative statements to the FFIEC IT Examination Handbooks. These are the same mappings in the CAT Appendix A.
  • NIST Mapping: mapping declarative statements to NIST.

ACET and Tandem

When the FFIEC Cybersecurity Assessment Tool (CAT) was first released, Tandem developed an application to aid in its use. Now Tandem has updated the tool to include the additional ACET features and to allow Credit Unions to complete the assessment through Tandem and download the results in the ACET spreadsheet format.  The Tandem SaaS comes in both a free and paid version.  Join more than 1,000 other financial institutions and sign up for the free Tandem Cybersecurity Assessment Tool today by visiting


What is Colorado Cybersecurity Regulation (HB 18-1128)?

On January 19, 2018, the General Assembly of the State of Colorado introduced House Bill 18-1128, Concerning Strengthening Protections for Consumer Data Privacy. The regulation was signed into law on May 29, 2018 and goes into effect on September 1, 2018.

The new regulation contains four primary sections:

  1. Disposal of Personal Identifying Information
  2. Protection of Personal Identifying Information
  3. Notification of Security Breach
  4. Security Breaches and Personal Information

The first three sections focus on how a "covered entity" can protect personal identifying information (PII). A "covered entity" is defined as a "person" (e.g., an individual, corporation, business trust, etc.) who maintains, owns, or licenses PII in the course of their business, vocation, or occupation.

Section Four shifts some wording around, but repeats the first three sections, replacing the term "covered entities" with "governmental entities."

Does Colorado HB 18-1128 apply to Banks and Credit Unions?

Yes. While the regulation defines PII a couple different ways, both definitions include things a financial institution would "maintain, own, or license" in the course of normal business (e.g., social security numbers, credit cards, debit cards, account numbers, etc.). If you are a financial institution in the State of Colorado, Colorado HB 18-1128 applies to you.

Are Financial Institutions in Compliance with Colorado HB 18-1128?

Let's break this down by section.

  • Section One: Yes.
    Financial institutions are already subject to GLBA, so the organization should already have a policy in place that defines the secure disposal of paper and electronic documents containing PII.
  • Section Two: Yes.

Again, since financial institutions are already subject to GLBA, the organization should already have reasonable security procedures and practices in place to protect PII from unauthorized access, use, modification, disclosure, or destruction.

  • Section Three: Partially.

Per GLBA, each financial institution should have an incident response policy, program, and/or plan that outlines what the organization should do in the event of a security breach. However, Section Three additionally includes new requirements, specific to the State of Colorado, about classification and notification of a security breach.

For example, Section 3(2)(e) states that if the security breach affected more than 500 Colorado residents, the covered entity must notify the Colorado Attorney General as soon as possible, but no later than 30 days after determining a security breach occurred. This requirement is new and it is specific to Colorado organizations, so it does not likely exist in your current incident response policy, program, and/or plan.

How to Prepare for September 1st

To prepare for the September 1st effective date, it would be beneficial for each financial institution to compare their existing incident response policy with the new requirements in Section Three and make updates, as needed.

We have developed a downloadable PDF called, "Understanding & Preparing for the Colorado Cybersecurity Regulation (HB 18-1128)." This document provides a side-by-side comparison of the regulatory language with our opinion to help you simplify and interpret the regulatory wording. This document will help you understand the regulation, as you prepare your institution for the September 1st deadline.

For Tandem Customers: The resource also provides information about how the requirements of HB 18-1128 are already addressed in Tandem, including recommendations about how you can incorporate the Colorado-specific requirements into your existing information security program.

What is Tandem?

Tandem is an online information security and compliance software designed to increase security and help financial institutions stay in compliance with GLBA and FFIEC guidance. Tandem is now being utilized by financial institutions across the country and helps by saving both time and money without sacrificing information security, cybersecurity, or compliance.


By: (Security+)

How do you know what due diligence documents to gather from each of your vendors? There are many methods available, but some result in more accurate documentation than others. Today, I'm going to review two of the primary methods and discuss the effectiveness of each method.

Method #1: The Bucket Method

I often see, what I will call, the bucket method.

It Goes Something like This

Imagine you have a list of questions you ask about vendor characteristics, and then you classify that vendor based on the number of questions answered as "yes." For example, a vendor should be considered:

  • "Level 1" if two or less are answered as "yes."
  • "Level 2" if three to four are answered as "yes."
  • "Level 3" if five or more are answered as "yes."

Then, you could define the required due diligence based on the level of the vendor, or based on the bucket in which the vendor is grouped. At "Level 1," collect only a service level agreement. At "Level 2," collect a contract, a confidentiality agreement, and financial statements. At "Level 3," collect all document types (e.g., a contract, confidentiality agreement, financial statements, SOC report, examination report, BCP, etc.).

What Happens Now?

This method seems relatively simple to carry out. But in reality, it can create a lot of unnecessary document exceptions, and occasionally miss opportunities to request relevant documents.

  • Unnecessary Document Exceptions in a Bucket Method
    Consider a vendor who is "Level 3." While five characteristics applied to them, several of the required documents are both unnecessary to request, and at some rate, unreasonable. This results in an exception record to explain each case and ultimately, requires more effort from you, as the vendor manager, to oversee the relationship.

  • Missed Opportunities for Requesting Relevant Documents in a Bucket Method
    Consider a vendor who is "Level 2." While only three characteristics applied to the vendor, one of them is very important. If this vendor were to be unavailable for 24 hours, it would be detrimental for our business. We should get their BCP, but we did not because it was not required for "Level 2" vendors.
What This Means for You

The bucket method costs a lot of time and effort even though the labelling process seems quick and simple.

[Learn how to review your 3rd party vendor SOC reports in 15 minutes or less. Plus, download our free SOC review checklist.]

Method #2: The If-Then Method

Instead of the bucket method, consider the more accurate if-then method.

It Goes Something like This

Imagine you have a list of questions you ask about vendor characteristics. You could say that if you answer Question A as "yes," then you should collect a specific type of document related to the effects of that characteristic, Document A. Here are a few examples to consider:

  • If a vendor performs critical functions or provides critical services, then you should get a service level agreement.
  • If a vendor uses subcontractors in the performance of critical functions, then you should get their Third party Due Diligence of Subcontracts.
  • If a vendor stores customer information, then you should get a SOC report.

method for collecting vendor management due diligence documents

What Happens Now?

By using the if-then method, you only gather the documentation that is appropriate to the third party relationship. This method can be continually refined. If you notice you are creating a lot of document exceptions for a specific type of document, revisit the question you are asking that instigates this requirement. Consider what assumptions are being incorrectly made about the characteristic's effects. Update your list to appropriately account for this.

Let's say you thought, "If a vendor stores, transmits, or accesses customer data, then I should get their SOC report." You would quickly find that not every vendor who can access your customer's data is going to have a SOC report, and that the SOC report is quite unnecessary for the service you are receiving. In this case, you could create two separate questions. One question would be about storing customer data, in which you would require a SOC report. Then another about accessing and transmitting customer data, in which you would require a confidentiality agreement, but not a SOC report. Making this adjustment would greatly reduce the number of documented exceptions.

What This Means for You

The if-then method will eliminate unnecessary document requests and ensure pertinent documents are obtained.

In Summary

While both methods provide standardized ways to gather due diligence documentation from vendors, the bucket method can actually cause more problems for your vendor managers.  By using the if-then method, you can manage your vendors based on the services that are being provided to you and easily change your program to meet the developing needs of your environment. Couple this method with the Tandem Vendor Management Software, and increase the efficiency in which you conduct your program. 



Early this year the tech world was rocked with the announcement of two unprecedented vulnerabilities named Meltdown and Spectre.

These two vulnerabilities are a big deal because they are hardware vulnerabilities affecting any device with a silicon chip. This includes microprocessors on workstations and servers, mobile phones, tablets, cloud services, and other platforms.

Understandably there was a rush from three main industries, processor companies, operating system companies, and cloud providers to provide solutions. However, as a result of the urgent response, there were unanticipated update incompatibilities which crashed systems. This created a dilemma for IT professionals. "Do we install updates which may cause our systems to crash?" or "Do we sit-tight and remain vulnerable?"

Even in the weeks of uncertainty, there were calm voices of seasoned reasoning. Their message reminded us that basic security standards remain our first line of defense. No matter how bad an exploit may be, its impact can be limited if:

  • The vulnerability doesn't have access to your systems
  • Operating system or application weaknesses are patched
  • Security software is installed (advanced end-point protection software with artificial intelligence is a game changer)

So how do you do achieve these standards? Here are some fundamental best practices:

  1. Monitor availability of operating system and application updates. Be sure you find and establish good sources to inform you about the patches and updates for your systems and applications. Then, monitor the sources or subscribe to notifications.

  2. Test updates to ensure compatibility. It is best if your update and patching process includes a test environment where non-production systems are updated first in order to test functionality and compatibility. This allows you to postpone or avoid updates which might crash systems or applications.

  3. Apply updates and patches on a regular schedule. As a best practice, you should implement a schedule (at least monthly) to evaluate, test and install updates for systems and critical applications. In this way, your schedule can coincide with schedules of operating system and application vendors (e.g., Microsoft has "Patch Tuesday, the second Tuesday of each month).

  4. Install and maintain security software (e.g., antivirus software, endpoint security software, etc.). If possible, explore and utilize behavior based end-point protection software. This genre of software "watches" system behavior to notice and stop suspicious action.

  5. Prevent malicious code execution. The goal is to keep malicious code out of your network and systems. This is best accomplished with layers of security including Internet filtering, phishing detection, and security awareness training for system users. Security awareness is essential to help prevent users from falling prey to malicious emails.


By: (Security+)

Ideally, reviewing a SOC Report will take you 15 minutes or less (once you get the hang of it). If you are a financial institution and you have vendors, then you have plenty of SOC Reports to review every year.

This blog will tell you what to review in SOC Reports, and nothing more.

You Don't Have to Know It All

I could tell you all sorts of information about SSAE 18 and SOC Reports! Here's one: SSAE 18 is the rule book and SOC is the engagement and report name, so you don't get a SSAE 18 from your vendor, you get a SOC Report. But what you actually want/need is a quick way to get your job done, not a dissertation on the inner working of SOC audits.

Other people may try to make the SOC Report review process seem big and complex so that you will rely on them to do the reviews for you… Don't let them scare you. You are capable of reviewing a SOC Report just as well as any expert. Really! I believe in you.

Admittedly, SOC Reports are complex and they are full of important information, but finding the information you need from it is really quite simple.

You Just Need the Important Parts

Think about this: If your vendor has a SOC Report, then that means an outside party has reviewed the vendor on your behalf. The outside party has verified the vendor is operating effectively. Thanks to this outside party, you don't have to comb over every detail of a SOC report. This means you can primarily read the cliff-notes version in the "Auditor's Report" section and trust the outside party's judgment.

SOC reports are completely standardized. They share a basic structure and even include some of the exact same sentences. This means you can grab what you need from a few specific places, then be on your way.

Let's Get To It

Here is a quick list of the information you need to find in a vendor's SOC report and note in your review. Section names won't be exact, but they're pretty close.

Look at the Cover Page to compile a profile for this SOC report. Find the company being reviewed, the auditing firm, SOC #, and Type #.

Look at the Scope subsection of the Auditor's Report section to find when the audit was done.

Now, this is one of the two most important parts of your review, so focus with me here. Look at the Scope subsection of the Auditor's Report section to see if complementary user entity controls are employed. If so, go to the Description of Systems section to find all of the details about the complementary user entity controls. And obviously, make sure you are doing those things.

Look at the Scope subsection of the Auditor's Report section to see if subservice provider controls are employed. If so, go to the Description of Systems section to find out what the vendor is doing to monitor the subservice provider controls.

Look at the Limitations subsection of the Auditor's Report section to see if anything happened during the audit that limited the auditor's ability to check everything.

This is the other of the two most important parts of your review. Look at the Opinion subsection of the Auditor's Report section to see if the auditor found anything problematic. Also note their official "opinion." If the auditor noted significant issues, find the Other section. Management should provide some kind of response to the significant issues found.

If this was a Type 2 engagement, look at the Test Results section to find any and all exceptions encountered during testing. This may include some that were not considered significant enough for the auditor to mention in the Opinion subsection.

And that's it. While it's pretty simple, why not make it easier? We created a downloadable PDF with the above checklist so that you can easily and efficiently review your SOC reports.


In September 2016, the Federal Financial Institutions Examination Council (FFIEC) released an updated Information Security Booklet as part of the IT Examination Handbook. Among other contemporary concepts, the FFIEC placed an increased emphasis on the role of Information Security Officers (ISOs) in financial institutions. In section I.B Responsibility and Accountability (Page 5), the FFIEC provides a list of six key qualities of the ISO role. Here are the six qualities and a brief interpretation of how this can be applied in your organization.

1. Sufficient Authority

Each ISO should have sufficient authority to perform their assigned tasks. While the ISO ultimately reports to the board or senior management, they must also be a trusted employee (or group of employees) who is authorized to make organization-altering decisions on their own. In short, your ISO should be someone you can, and will, trust.

2. Stature within the Organization

Each ISO should have stature within the organization to perform their assigned tasks. In addition to being a trustworthy part of the organization, the ISO should also be a respected part of the organization. The role of the ISO is a position that should be held with esteem. This is a tone that is set from the top. If the board and senior management respect the role of the ISO, the organization's employees will respect it, as well.

3. Knowledge

Each ISO should have knowledge to perform their assigned tasks. The ISO is tasked with oversight of the information security program. This is a broad-scoped topic which requires knowledge of the physical, technical, and administrative functions of the organization. If no one employee has sufficient knowledge to make decisions for each of these areas, it may be wise to consider appointing multiple individuals to fill the organization's ISO role as a committee.

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4. Background

Each ISO should have background to perform their assigned tasks. Similar to knowledge, the ISO should have a history that involves information security. An employee can be trustworthy, respectable, and have knowledge of information security, but be lacking a foundation of experience. Information security is an ever-changing field. Appointing an ISO who does not have experience in the field is a risk to the organization's information security.

5. Training

Each ISO should have continued training to perform their assigned tasks. Since the field is ever-changing, it should not be assumed that the ISO has all the training required to perform their duty. As the threat environment changes, as new controls are implemented, as the industry advances, the board and senior management should expect the ISO or members of the ISO team to further their education through training.

6. Independence

Each ISO should have independence to perform their assigned tasks. It would be best to avoid conflicts of interest when selecting an ISO. For example, while knowledge of information technology (IT) is important, the ISO should not be the person responsible for implementing the organization's IT function. For community financial institutions, this is not always practical. So, if your organization finds independence difficult, it may be beneficial to appoint individuals from various departments to fill the organization's ISO role as a committee.

In Summary…

While the FFIEC may not be very prescriptive when it comes to appointing an ISO, by ensuring your organization's ISO is trustworthy, respectable, knowledgeable, experienced, interested in learning, and independent of other functions in the organization, your organization can lay the foundation for an effective information security program.