Blog: Financial Institutions

This article was updated on August 28, 2019. See below for the updates.

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.

August 2019 Update: In July 2019, the OCC replied to a comment from the FSSCC in the Federal Register. The FSSCC asked the agencies to "make a clear statement that other methodologies, such as NIST Cybersecurity Framework and the FSSCC Cybersecurity Profile, are acceptable inputs into the examination process." The OCC replied that financial institutions "may choose to use the [FFIEC CAT], the NIST Cybersecurity Framework, or any other risk assessment process or tool to assess cybersecurity risk."

• 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.

August 2019 Update: In August 2019, the FFIEC published a press release encouraging a standardized approach to assessing cybersecurity preparedness. 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."

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 techsales@conetrix.com if you want more information about the differences between Aspire private cloud hosting and Office 365.


 

By: (CISA, CISSP)

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.

 

On September 9th, 2016, the Federal Financial Institutions Examination Council (FFIEC) released a revised Information Security booklet.  This booklet is one of eleven booklets that make up the FFIEC Information Technology Examination Handbook (FFIEC IT Handbook). The IT Handbook is designed to provide information and reference to financial institutions and examiners.  The Information Security booklet specifically “provides guidance to examiners and addresses factors necessary to assess the level of security risks to a financial institution’s information systems.”

To learn more about the new FFIEC Information Security Booklet, join us for a webinar on October 11th at 2:00pm CDT. Register now

To see other webinars offered by CoNetrix, visit our webinars page.

About the FFIEC: The FFIEC was established in 1979 per Title X of the Financial Institutions Regulatory and Interest Rate Control Act of 1978.  The FFIEC is comprised of the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), the National Credit Union Administrator (NCUA), the Office of the Comptroller of the Currency (OCC), the State Liaison Committee (SLC), and the Consumer Financial Protection Bureau (CFPB).

 


 

Today the FFIEC released a Cybersecurity Assessment Tool to help financial institutions identify their risks and assess their cybersecurity preparedness.  The assessment tool is designed to provide a repeatable and measurable process for banks and credit unions to measure their cybersecurity preparedness over time.

The FFIEC tool consists of pdf documents including an Overview for Chief Executive Officers and Boards of Directors, a User's Guide, an Inherent Risk Profile, a Cybersecurity Maturity, and some Additional Resources.

CoNetrix is working on a FREE online, interactive tool to assist banks and credit unions in completing the new FFIEC cybersecurity assessment.  This easy to use SaaS will allow financial institutions to answer questions provided in the FFIEC documents, view and analyze inherent risk and cybersecurity maturity, and run various reports.  To learn more about the new Tandem Cybersecurity tool, visit https://conetrix.com/cybersecurity.

 


 

The ".bank" domain registration will open into general availability on June 24, 2015 at 00:00:00 UTC or June 23 at 8:00pm Eastern, 7:00pm Central, 6:00pm Mountain, & 5:00pm Pacific.  According to fTLD, during the initial sunrise regstration period, there were more than 700 applications made for ".bank" domains.  Domains will be awarded on a first-come, first-served basis in all registration periods.  To learn more, read the article Dot Bank by Leticia Saiid of CoNetrix published in the Spring 2015 issue of The Community Banker or visit www.ftld.com.


 

Registration for the new “.bank” domains is coming up soon. These domains could be prime Internet names in the future. A few quick notes: [more] 

  • Early “sunrise” registration will be May 18, 2015 with general availability on June 24th.
  • Registration will be limited to domain names with corresponding trademark, trade name, service mark, or bank name. 
  • There will be a verification procedure to ensure these domain names are only issued to valid financial institutions.
  • Banks should consider registering a trademark now to be able to register the associated domain during the sunrise registration period. 
  • Registration will be on a “first come, first serve” basis, so if a bank with similar names want the good domains, they need to register early.
  • More information is available at https://www.ftld.com

 


 

The Federal Financial Institutions Examination Council (FFIEC) today launched a web page dedicated to cybersecurity (http://www.ffiec.gov/cybersecurity.htm). The website is designed to be "a central repository for current and future FFIEC-related materials on cybersecurity." [more]

As a part of the Press Release announcing the launch of the cybersecurity web page, the FFIEC also noted the launch of the website "coincides with a pilot program at more than 500 community institutions, to be conducted by state and federal regulators, which will be completed during regularly scheduled examinations."  According to the press release, the focus of the pilot program will be on:

  1. Risk Management and Oversight
  2. Threat Intelligence and Collaboration
  3. Cybersecurity Controls
  4. Service Provider and Vendor Risk Management
  5. Cyber Incident Management and Resilience
The pilot program is expected to last about 4 weeks and include regulators from the FDIC, OCC, Federal Reserve, NCUA, and the States.

 

The Federal Financial Institutions Examination Council (FFIEC) issued statements today notifying financial institutions of the risks associated with cyber-attacks on Automated Teller Machines (ATM) and car authorization systems and the continued distributed denial of service (DDoS) attacks. [more]

To read the Press Release, visit http://www.ffiec.gov/press/pr040214.htm

To view the Joint Statement, Cyber-attacks on Financial Institutions' ATM and Card Authorization Systems, visit http://www.ffiec.gov/press/PDF/FFIEC%20ATM%20Cash-Out%20Statement.pdf

To view the Joint Statement, Distributed Denial-of-Service (DDoS) Cyber-Attacks, Risk Mitigation, and Additional Resources, visit http://www.ffiec.gov/press/PDF/FFIEC%20DDoS%20Joint%20Statement.pdf