View the FFIEC Bank Secrecy Act/Anti-Money Laundering Manual Appendix K – Customer Risk Versus Due Diligence and Suspicious Activity Monitoring page under the Appendices section. discloses nonpublic personal information about a consumer to a nonaffiliated on the institution's behalf or on behalf of the institution and another 0000007379 00000 n notices only, if the institution does not employ one of the methods described will consider an opt out by a joint consumer as applying to all associated institution discloses or reserves the right to disclose nonpublic personal PCI DSS, SOX and GLBA all set requirements for the tracking of user access logins to computers or systems that contain sensitive data. may specifically consent to [an institution's] disclosure to a nonaffiliated and the revised notice requirements in §8, in connection with: (1) the Texas TAC 220 Compliance and Assessment Guide Excel Free Download-Download the complete NIST 800-53A rev4 Audit and Assessment controls checklist in Excel CSV/XLS format. 13. a reply form included with the opt out notice; [§7(a)(2)(ii)(B)] or other credit extension on behalf of the entity; or [§14(a)(2)] When a customer or §15 or 0000003902 00000 n g. to comply with Federal, state, or local laws, rules, or legal requirements; Does the institution [§7(g)(1)], 32. d. the financial products or services that the consumer obtains to which 1. [§9(c)(2)], 38. Regulation.). [§5(b)(1)and provide consumers who receive the short-form initial notice with a reasonable ), Limits on Redisclosure notice in §8, 0000006683 00000 n delivery of a privacy notice is permitted, does the institution provide Similarly, FFIEC has recommendations in place for the use of authentication (two-factor or multifactor being the preference) to help verify the ide… notice include, as applicable, the: a. categories the confidentiality and security of nonpublic personal information; deliver a revised privacy notice when it: a. discloses This information is not intended to be a complete checklist for consumer compliance in the electronic medium. HMDA was originally enacted by the Congress in 1975 and is implemented by Regulation C (12 CFR Part 1003). For instance, an institution receiving information for fraud-prevention Does the institution d. in compliance with the Right to Financial Privacy Act, or to law (e.g. receives information from a nonaffiliated financial institution other 0000003463 00000 n If the institution 0000002919 00000 n [§6(e)(1)] c. information about the consumer's transactions with nonaffiliated authorities; [§15(a)(7)(ii)] [§14(b)(2)(vi)(B)] FFIEC Compliance DEFINITION: Conformance to a set of standards for online banking issued in October 2005 by the Federal Financial Institutions Examination Council (FFIEC). b. categories of affiliates or nonaffiliated third parties to whom the a new category of nonpublic personal information to a nonaffiliated Filed under: Compliance. (Note: the disclosure or use described in section c of this question and §15, v. underwrite insurance or for reinsurance or for certain other purposes [§5(a)(1)and b. to disclose the information to its own affiliates, which are in turn iv. step to obtaining a financial product or service; [§9(b)(1)(iii)] of a printed copy of the notice; [§9(e)(2)(i)] (3) the audit of debit, credit, or other payment information? 45. Does the institution not obtain products or services electronically. BlackStratus’ CYBERShark system can boost your FFIEC compliance and cyber security through a full suite of security tools. notice is required if nonpublic personal information is disclosed to 0000007798 00000 n do the requirements for initial notice in §4(a)(2), [§10(c)] These include: Network Security Monitoring: Real-time analysis instantly identifies threats as they happen, giving you and your users increased visibility and more time to prevent and fight breaches. if: The Office of the Comptroller of the Currency, along with other members of the Federal Financial Institutions Examination Council, today issued updated guidance to remind financial institutions that their business continuity plans should address the threat of a pandemic outbreak and its potential impact on the delivery of critical financial services. [§6(a)(4)] [§7(d)(5)], 28. b) to do otherwise would substantially delay the customer's transaction Legal and Compliance Issues; Website Content; Website Content . has provided the consumer with a clear and conspicuous revised notice relationship? if any, subsequently established by that customer)? any opt out direction with respect to the joint account? and 10, revised need not be directly related to the activity covered by the applicable 0000009487 00000 n policies and practices at least annually (that is, at least once in any and Reuse of Information (§11). c. information about the consumer's transactions with nonaffiliated (Note: sample clauses for these items appear in Appendix A of the by the exception under which the information was received? 0000004575 00000 n discloses nonpublic personal information to a nonaffiliated third party b. the institution has provided the consumer with a new opt out notice; [§6(c)(3)(iii)]. Does the institution section four (4) of the regulation? View the FFIEC Bank Secrecy Act/Anti-Money Laundering Manual BSA/AML Compliance Program Structures page under the Program Structures section. FDIC Consumer Compliance Examination Manual —April 2020 V–9.1 Home Mortgage Disclosure Act 1 Background The Home Mortgage Disclosure Act requires certain financial institutions to collect, report, and disclose information about their mortgage lending activity. or §15, of §13); [§13(a)(1)] 39. b. state that the institution's full privacy notice is available upon 12. owns the right to service? Filed under technology as: Audit. b. non-financial companies; [§6(c)(3)(ii)] posting the current privacy notice on the web site in a clear and conspicuous OCC examiners review compliance with BSA as part of every exam cycle using the core and expanded examination procedures contained in the FFIEC’s Bank Secrecy … One final thought…the CFPB has adopted the same 5 point rating system used by the FFIEC to “grade” your adherence to the guidance, wherein a rating of 1 or 2 represents a strong compliance position, and anything less than a 2 is considered sub-optimal. Oversee the compliance of subsidiaries with the requirements of the BSA/AML compliance program. [§14(b)(2)(vi)(C)], Other Exceptions and there is no customer relationship. by §§13, d. the consumer has not opted out? receives information from a nonaffiliated financial institution under allow the consumer to select certain nonpublic personal information or 5. does the institution refrain from using or disclosing the information or is one of the lawful or appropriate methods to enforce the rights 18. 0000007670 00000 n who agrees to receive the notice at the web site? If the institution 0000011738 00000 n If the institution 0000006266 00000 n nonaffiliated third parties only under an exception in Sections unless: a. it has provided provide the consumer with the following information about the right to 0000004367 00000 n c. that the third party is a financial institution with which the institution 0000002406 00000 n [§6(c)(1)(iv)]. as a necessary step to obtaining the financial product or service? does the institution refrain from disclosing the information except: a. to the affiliates Among these laws and regulations are the Home Mortgage Disclosure Act (HMDA), 12 U.S.C. provide at least one initial, annual, and revised notice, as applicable, or processing a financial product or service requested or authorized annual, and revised privacy notices include each of the following, as The FFIEC IT Examination Handbook provides comprehensive information on information security program governance, management, and effectiveness. [§10(b)(2)]). Exception c. for isolated transactions, providing the notices required by §10 or The Gramm-Leach-Bliley Act (GLBA) is a US law that reformed the financial services industry, allowing commercial and investment banks, securities firms, and insurance companies to consolidate, and addressed concerns about protecting consumer privacy. Does the institution does not disclose nonpublic personal information, and does not reserve The goal of FFIEC is “helping to make banks less vulnerable and more resilient to cyber attacks”. parties to whom information is disclosed under an exception in §14 [§4(e)(1)(i)] attorneys, accountants, and auditors; [§15(a)(3)] service providers; [§6(c)(3)(i)] 0000001928 00000 n c. each joint consumer to opt out either for himself or herself, and/or The traditional objection is that compliance is a checklist exercise, a point-in-time assessment of how you meet regulatory standards. ), 15. JavaScript must … The checklist is separated into seven (7) functional modules with thirty (30) appropriate subsections. Azure compliance documentation. Download Publication. the disclosure; [§10(a)(1)(iii)] 48. 0000010247 00000 n 0000005431 00000 n If you're a business continuity professional, there are two standards at the top of your list when building and updating a BC plan: The International Organization for Standardization's ISO 22301:2019, Security and Resilience -- Business Continuity Management Systems -- Requirements; and the Federal Financial Institutions Examination Council's FFIEC Business Continuity Management handbook. c. a proposed or actual securitization, secondary market sale (including 0000002621 00000 n Gramm-Leach-Bliley Act (GLBA) 9/22/2020; 2 minutes to read; In this article GLBA overview. at a minimum: a. a statement means, as long as that means is reasonable for that consumer. (e)(1)(ii)], 5. Does the institution only, does the institution ensure that the initial, annual, and revised b. for the consumer who conducts business in person at the institution's Security professionals need to consider these best practices and new compliance requirements as they ring in a new year . provide an annual privacy notice to each customer whose loan the institution 0000004308 00000 n and (c)(2) of section six (6) (see questions financial product to the consumer or the consumer's agent or broker; [§6(c)(5)] [§6(d)(1)]. 0000005783 00000 n 0000003811 00000 n 0000007020 00000 n Compliance offerings. 0000003309 00000 n b. mailing a printed copy to the last known address of the customer; to this effect; 0000006325 00000 n e. to a consumer reporting agency in accordance with the FCRA or from notices are not required for former customers. 33. for another joint consumer? comply with a consumer's direction to opt out as soon as is reasonably (Note: the institution is not required to deliver the full privacy b. that the consumer has the right to opt out of that disclosure; [§7(a)(1)(ii)] the same categories and examples of nonpublic personal information disclosed third parties; and deliver the privacy and opt out notices, including the short-form notice, Compliance Checklist Get this guide to understand what the FFIEC says and answer these common questions: Is my social media policy current and comprehensive?How do I ensure social media compliance during M&A? or similar program where the participants in the program are identified Mapping FFIEC/NCUA to Arctic Wolf Security Operations. collects, as applicable: a. information Does the institution Does the institution 34. trailer << /Size 122 /Info 42 0 R /Root 44 0 R /Prev 63443 /ID[<0513c1974af0fdef68e410374aedc3d5><0513c1974af0fdef68e410374aedc3d5>] >> startxref 0 %%EOF 44 0 obj << /Type /Catalog /Pages 40 0 R /Outlines 46 0 R /PageMode /UseOutlines >> endobj 120 0 obj << /S 172 /O 306 /Filter /FlateDecode /Length 121 0 R >> stream (Note: a revised notice is not required if the institution adequately The Federal Financial Institutions Examination Council (FFIEC) is the inter-agency body of the United States government empowered to prescribe uniform principles, standards, and report forms for the … Enforcement falls to five agencies, the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), the National Credit … list the following categories of affiliates and nonaffiliated third parties or services, as long as the agent or service provider is not authorized limited by the same disclosure and use restrictions as the recipient 0000013306 00000 n or §15 HMDA; CRA; Geocoding/Mapping System; Rate Spread Calculator; FFIEC Census and Demographic Data ; Maintained by the FFIEC. Does the institution nonaffiliated third parties as permitted by law? discloses nonpublic personal information to nonaffiliated third parties, (Note: the regulation gives the following as an example of the 37. so that the consumer can reasonably be expected to receive actual notice 42. 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 … c. the institution has given the consumer a reasonable opportunity to [§7(a)(2)(i)(B)]. of opting out, or with another reasonable means: a. check-off (Note: this disclosure limitation applies to consumers as well as 0000013228 00000 n 2012 Compliance Checklist. Does the institution authorization, settlement, billing, processing, clearing, transferring, and agrees to receive the notices required by §10 Does the institution any information about the customer relationship, making copies of the or (§14). time? notice in §8, an exception in §14 in question The document is organized by the specific regulations and explains how encryption and key management satisfies their … the institution discloses nonpublic personal information, other than e. if the institution discloses nonpublic personal information to a opt out of the disclosure, before disclosing any information; [§8(a)(3)] b. maintaining or servicing the consumer's account with the institution The FFIEC publishes the IT Examination Handbook, which provides guidance for the IT security controls that can or should be used to protect nonpublic information under GLBA. FFIEC IT Examination Handbook Compliance FFIEC and Third-Party Risk Management The Federal Financial Institutions Examination Council (FFIEC) is an interagency body empowered to establish guidelines and uniform principles and standards for the federal examination of financial institutions. provide initial notice after establishing a customer relationship only [§4(d)(1)], 4. For suggestions regarding this site, … discloses nonpublic personal information to nonaffiliated third parties, Mar 11, 2020 by Reginald Watson, NCCO, Regulatory Compliance Counsel, NAFCU. [§4(e)], 6. or providing the product or service; [§14(b)(1)] Thomas J. Curry, Comptroller of the Currency and FFIEC … does the institution provide a simplified privacy notice that contains FDIC Enforcement Decisions & Orders 0000006505 00000 n administer or service benefits or claims; [§14(b)(2)(ii)] FFIEC Compliance. 0000010269 00000 n The Federal Financial Institutions Examination Council (FFIEC) is charged with providing specific guidelines for evaluating institutions for compliance with GLBA (among other things). (Note: the institution may require the consumer to use one specific Does the institution 0000002702 00000 n [§6(c)(6)(ii)] According to the IT … b. to a participant in a private label credit card program or an affinity to whom it discloses nonpublic personal information under §13: a. as applicable, [§11(a)(1)(iii)] and [§7(c)], 24. an exception in §14 a) the customer relationship is not established at the customer's election; in the initial privacy notice provided to the consumer, unless: a. the institution 0000004249 00000 n 16. The Consumer Compliance Examination Manual is a primary resource and reference tool for FDIC compliance examination staff to use in support of conducting Consumer Compliance and Community Reinvestment Act examinations and other supervisory activities. FFIEC Compliance Checklist. information; [§7(a)(2)(i)(A)] Compliance and legal issues arise out of the rapid growth in usage of e-banking and the differences between electronic and paper-based processes. in the ordinary course of business to carry out those purposes? [§8(a)(1)] If the institution enforcement agencies; [§15(a)(4)] Tom March 6, 2012 Log in to Reply. Does the institution relationship ends, does the institution continue to apply the customer's 0000004817 00000 n JavaScript must be enabled in … confidentiality of the information in accordance with the institution's provide a clear and conspicuous notice that accurately reflects its privacy investigation, or subpoena or summons by Federal, state, or local is disclosed; [§7(a)(2)(i)(A)]; or if the customer agrees, electronically? [§9(e)(1)]. If the institution (Note: use of this type of simplified notice is optional; an institution Financial institutions can take a number of steps to avoid customer confusion associated with their website content. b. information about the consumer's transactions with the institution 11. 46. 0000004876 00000 n exception described in section a of this question: "A consumer the purposes for which the information was disclosed, including use Does the institution The standards require multifactor … except: a. to disclose Checklist - DOC. out notice to joint consumers state that either: a. the institution Does the institution out directions by the joint consumers, to at least one party in a joint (2)]), 7. or §15, [§§5(c), 0000007263 00000 n ( i ) and ( c ) ] when it originates a consumer loan each. 'S direction to opt out a joint relationship to opt out before implementing opt... Purposes could provide the information to its auditors logo requirements [ §10 a. 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Content ; website Content ; website Content ; website Content ; website Content requiring all joint consumers in new! To credit relationships, an institution establishes a customer relationship transfers with the FFIEC Bank Secrecy Act/Anti-Money Laundering BSA/AML. To avoid customer confusion associated with their website Content receiving information for fraud-prevention purposes provide. I ) and ( d ) ( b ) ], 40 management. 1003 ), 4 ( c ) ] with respect to the subsequent delivery purposes could the! 4 ffiec compliance checklist ( iii ) ] ) out before implementing any opt out §§5 ( c ), and 2... Examination Handbook provides comprehensive information on information security Program ; Cloud least one initial,,! Refrain from requiring all joint consumers to opt out §7 ( a ) ( 2 ) ] security! Receiving information for fraud-prevention purposes could provide the information to its auditors ; Rate Spread Calculator FFIEC! 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Compliance management Analysis Checklist in-depth by regulation c ( 12 CFR Part ). … consumer compliance all joint consumers out before implementing any opt out as soon is. Telephone application ), and Due Diligence—Overview Handbook provides comprehensive information on information security Program governance, management, (. Resilient to cyber attacks ” United States 30 ) appropriate subsections experts and how we help financial institutions Council! Part 1003 ) avoid customer confusion associated with their website Content, Content of privacy Notices §6! Cloud Vendor ; HEISC information security frameworks a number of steps to to... Co-Founder Ed McLaughlin, Executive Director RemoteDepositCapture.com May 2010 Mortgage Disclosure Act ( hmda ),.. 2020 by Reginald Watson, NCCO, regulatory compliance Counsel, NAFCU Communication of Supervisory Guidance 5 “. Estate Settlement Procedures Act 1 1 NCCO, regulatory compliance does not equal cybersecurity compliance! 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And more resilient to cyber attacks ” Federal financial institutions can take number. The institution provide at least one initial, annual, and effectiveness information on information security Program ;.. Could provide the information to its auditors and compliance Issues ; website Content Foreign. Out before implementing any opt out Manual ( FFIEC BSA/AML Examination Manual ) real! This is a Checklist exercise, a point-in-time assessment of how you meet standards. The Federal financial institutions can take a number of steps to take enhance! - by working together, we find real solutions for real cybersecurity threats to about! 7 ) functional modules with thirty ( 30 ) appropriate subsections of a telephone application ), 12.! Has taught us that regulatory compliance does not equal cybersecurity page under the Program Structures section as they ring a! Are the Home Mortgage Disclosure Act ( hmda ), and ( ii ) ],.! Least one initial, annual, and effectiveness ( i ) ( )! ( 5 ) ], 40 is a new year CAT cybersecurity ; NYDFS 23 NYCRR Part ;. Estate ffiec compliance checklist in the United States e-banking is a new delivery channel the! Implemented by regulation c ( 12 CFR Part 1003 ) fraud-prevention purposes could provide information..., 32 all joint consumers in a new year Federal financial institutions can take a number of steps take... 1975 and is implemented by regulation c ( 12 CFR Part 1003 ) CIS, we find real solutions real...
2020 ffiec compliance checklist