May 13, 2001
FYI - During an IS audit during the past year, it was
discovered that all the five day rotation backup tapes of the data
processing applications were not working. While the problem turned out to
be a defective backup tape drive, during the daily backup procedures the
system said that the backup was "successful." Testing the bank's
disaster recovery program brought this problem to light. The question is
even though your backup system indicates that the backup was successful,
are you sure? Testing your backup is the only sure means that the backup
system is working.
FYI - The FDIC issued guidance on measures to prevent identity
theft and pretext calling. The guidance reminds financial institutions how
to report such activities to regulators using Suspicious Activity Reports
(SARs), suggests educating consumers on identity theft and pretext
calling, and summarizes relevant federal laws. http://www.fdic.gov/news/news/press/2001/pr3601.html
FYI - The Board of Governors of the Federal Reserve System (FRB)
published the attached interim final rules establishing uniform standards
for the electronic delivery of federally mandated disclosures under five
consumer protection regulations: B (Equal Credit Opportunity), E
(Electronic Fund Transfers), M (Consumer Leasing), Z (Truth in Lending),
and DD (Truth in Savings). The rules took effect on March 30, 2001;
however, to allow time for any necessary operational changes, the
mandatory compliance date is October 1, 2001. http://www.fdic.gov/news/news/financial/2001/fil0140.html
INTERNET COMPLIANCE - Equal Credit Opportunity Act (Regulation B)
The regulations clarifies the rules concerning the taking of credit
applications by specifying that application information entered directly
into and retained by a computerized system qualifies as a written
application under this section. If an institution makes credit application
forms available through its on-line system, it must ensure that the forms
satisfy the requirements.
The regulations also clarify the regulatory requirements that apply
when an institution takes loan applications through electronic media. If
an applicant applies through an electronic medium (for example, the
Internet or a facsimile) without video capability that allows employees of
the institution to see the applicant, the institution may treat the
application as if it were received by mail.
INTERNET SECURITY - We continue the series from the FDIC "Security
Risks Associated with the Internet." While this Financial Institution
Letter was published in December 1997, the issues still are relevant.
Non-repudiation
Non-repudiation involves creating proof of the origin or delivery of
data to protect the sender against false denial by the recipient that the
data has been received or to protect the recipient against false denial by
the sender that the data has been sent. To ensure that a transaction is
enforceable, steps must be taken to prohibit parties from disputing the
validity of, or refusing to acknowledge, legitimate communications or
transactions.
Access Control / System Design
Establishing a link between a bank's internal network and the Internet
can create a number of additional access points into the internal
operating system. Furthermore, because the Internet is global,
unauthorized access attempts might be initiated from anywhere in the
world. These factors present a heightened risk to systems and data,
necessitating strong security measures to control access. Because the
security of any network is only as strong as its weakest link, the
functionality of all related systems must be protected from attack and
unauthorized access. Specific risks include the destruction, altering, or
theft of data or funds; compromised data confidentiality; denial of
service (system failures); a damaged public image; and resulting legal
implications. Perpetrators may include hackers, unscrupulous vendors,
former or disgruntled employees, or even agents of espionage.
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