Tag Archives: credit union

Ransomware-Proof Your Credit Union: A Checklist of NCUA Guidance

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In today’s digital landscape, credit unions face numerous cybersecurity threats, including the rising risk of ransomware attacks and vulnerabilities in their information and communications technology supply chain. To help credit unions protect themselves against these risks, the National Credit Union Administration (NCUA) has compiled an FAQ. This checklist covers the essential steps to safeguard against ransomware attacks, additional resources for cybersecurity, understanding supply chain risk management, developing effective practices, mitigating risks associated with using a Managed Service Provider (MSP), and other insights based on their FAQ. By following this checklist, credit unions can enhance their overall security posture and minimize the potential impact of cyber threats.

1. Protect against ransomware attacks:
– Update software and operating systems regularly with the latest patches.
– Avoid clicking on links or opening attachments in unsolicited emails.
– Follow safe browsing practices.
– Replace equipment running older unsupported operating systems.
– Verify the security practices of vendors and third-party service providers.
– Maintain complete and tested backups of critical systems and data.

2. Additional resources for cybersecurity:
– Use the Ransomware Self-Assessment Tool (R-SAT) from the Conference of State Bank Supervisors.
– Read the Center for Internet Security white paper on ransomware.
– Visit the cybersecurity pages of the National Security Agency Central Security Service and the Cybersecurity & Infrastructure Security Agency. (CISA)
– Refer to the Treasury Department’s advisory on potential sanctions risks for facilitating ransomware payments.

3. Understand Technology Supply Chain Risk Management (SCRM):
– Recognize that technology supply chain vulnerabilities can pose risks to the entire institution.
– Consider the risks associated with third-party vendors and the entire technology supply chain.
– Identify vulnerabilities in all phases of the product life cycle.

4. Develop an effective Technology Supply Chain Risk Management Practice:
– Build a team with representatives from various roles and functions.
– Document policies and procedures based on industry standards and best practices.
– Create a list of technology components and understand their criticality and remote access capability.
– Identify suppliers and verify their security practices.
– Assess and evaluate the SCRM program regularly.

5. Risks associated with using a Managed Service Provider (MSP):
– APT actors actively attempt to infiltrate IT service provider networks.
– Conduct proper due diligence and ongoing monitoring of MSPs.
– Understand the risks of centralizing information with an MSP.
– Recognize that compromises in an MSP’s network can have cascading effects.

6. Mitigate the risk of using an MSP:
– Manage supply chain risk by working with the MSP to address security concerns.
– Implement architecture measures to restrict access and protect networks.
– Use dedicated VPNs for MSP connections and restrict VPN traffic.
– Ensure proper authentication, authorization, and accounting practices.
– Implement operational controls, such as continuous monitoring and software updates.

7. Additional references for Information and Communications Technology Supply Chain Risk Management:
– Refer to guidance from the NCUA, NIST, and CISA.
– Evaluate third-party relationships and outsourcing technology services.
– Learn about supply chain threats and cyber supply chain risk management.

Note: This checklist is a summary of the information provided. For more detailed guidance, refer to the full content on the NCUA website.

 

* We used some AI tools to gather the information for this article.

Closing the CUSO Security Loop Hole

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The CUSO Security Loop Hole

The NCUA Inspector General (IG) suggested this week that the agency have regulatory oversight of Credit Union Service Organizations (CUSOs) to reduce the overall risk to the system. CUSOs have long been seen as a separate firm from the credit unions, though they may have an ownership stake in them. To date, many of these organizations have been outside the regulatory and oversight controls that are applied to the very credit unions they serve. In terms of information security, that often means they aren’t held to the same level of security and risk management controls as required by NCUA 748 and other guidance.

DigitalMoneyCUSO Security Oversight Challenges

The NCUA IG suggests that NCUA guidance and regulatory oversight be directly applied to CUSOs, instead of through vendor or partner risk management programs of the CUSO customers. This would provide for more direct regulation of the security controls and risk management processes in use at the CUSOs themselves. However, this introduces several challenges for some CUSOs, who may be more focused on agility, market speeds and innovation – areas where regulatory guidance can be especially impactful and can create significant budgetary challenges. This gets even more complicated when regulatory guidance is vague, or can be inflexible – the very opposite of the needs of organizations focused on innovation and market speed adaptation. An excellent example of this is CUSOs working on financial technologies, crypto currencies, blockchain and other exciting new areas. Regulatory guidance lags or lacks in most of those areas and hasn’t caught up to these new, and in some cases, experimental technologies.

One Approach – Best Practices CUSO Security and Third Party Attestation

One approach that might work, is for CUSOs to work with independent third-party assessors who could then measure the CUSO against industry standard best practices that apply to their specific lines of business, research or innovation. These vendors could then help the CUSO build a relevant and respectable CUSO security and risk management program – which they could attest to the NCUA. If this attestation were required on a yearly basis, along with some basic guidance, like ongoing risk management reviews, ongoing vulnerability management, etc – this could go a long way to mitigating the risks that concern the NCUA IG, while still maintaining independence and control by the CUSOs – thus, empowering their mission. Programs like these have been very successful in other industries and don’t have to add the overhead and bureaucracy of full regulatory compliance or programs like PCI-DSS. 

If you’d like to build such a program for your CUSO, please get in touch with us. We’d love to work on creating this process with a handful of CUSOs around the US, and are more than capable of applying our 30 years of experience in information security to each organization’s independent needs. Drop us a line or give us a call at (614) 351-1237 and let’s work together to close the CUSO Security loop hole in a way that reduces risk but doesn’t destroy the power and flexibility of the CUSO ecosystem.

Three Things I’ve Learned About Credit Union Risk Management

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I have been working with Credit Unions for more than 20 years and have done a wide variety of information security and risk management work over that time. I’ve worked with technical teams, management and boards over the span of more than two decades. Here are three things I’ve learned about how CUs manage risk during that time. 

1) Most credit unions that I’ve worked with care just as much, if not more, about information security than most of the regional size banks they often compete with.

I’ve heard more than one CU leader tell me that they have to be better than the banks, because when a bank gets hacked – that bank makes the news and feels the impact. However, he said, when a credit union gets hacked – all credit unions suffer from the bad press. I am not sure the data supports his claim, but it’s an example of how CUs often focus on working together to solve big problems, and put a lot more attention to detail into it.

2) Many of the credit unions I have worked with look at information security and threat awareness as something that they can offer to their members (“customers, in bank speak”).

More than a few of the CUs have engaged so deeply with their customers on phishing and identify theft, that they include them in discussions about what products and services the CU buys. They do trials, include members in beta-tests and I’ve even seen them do onsite training for how to use new multi-factor authentication tools – even ones that weren’t in use at the CU – just to help make the members more secure and reduce the threat of password re-use across personal sites.

3) The board is often more involved in the risk management process at my CU clients than my banking clients.

The NCUA has taken a lot of steps to increase board member awareness about information security, and it often shows at credit unions. Several times a year, I am asked to present threat updates or review the information security program of a CU, specifically with a presentation to the board in mind. I am often engaged as a third party, to spend a couple of days looking at a security program and reporting to the board on it’s maturity and areas of potential improvement.

During these board sessions, it is not uncommon for the board questions to last more than an hour, after the presentation has completed. The point is, most CU boards that I have worked with are deeply engaged in thinking about risk management at the credit union.

For those of you interested in more about risk management at credit unions, here are some of the best sources, which I refer to often in my presentations:

  • Credit unions also face such internal risks as internal fraud, legal and regulatory noncompliance, data breaches, and injuries to staff and visitors. (boardeffect.com)

  • The bottom line: Figuring out the risk appetite will help guide credit unions to create realistic and measurable risk guidelines. (visibleequity.com)

  • We have helped Credit Unions develop risk appetite statements and risk frameworks and can work with your Credit Union to develop the documentation you require. (creditunionupdate.com)

If you’d like to learn more about MSI and our work with credit unions, just drop us a line (info@microsolved.com) or give us a call (614-351-1237) and we’d be happy to talk about how we might be able to help your credit union excel in IT risk management.

Three Tips for Banking App Dev for Mobile Devices

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Lately, we have been looking at a lot of banking apps and front ends for the iPhone, Android and other mobile devices in the lab. Our testing thus far has shown some great results and it seems like a lot of banks, credit unions and other financial institutions are interested in having an “app” for their customers and members. Many of these apps are well designed, deep and rich. Many are simply canned front ends to existing web page content and functionality. A few are just plain horrible.

Here are three tips for organizations to keep in mind when coding their banking and financial apps for the mobile devices.

1. The mobile devices are not PCs. The apps should be light weight, clean and easy to use. Usability is tied to security in this case, because of errors. If your app has tiny little buttons with confusing text, no confirmation dialogs and lacks other basic usability features then you make it easier for users to make mistakes, create bad transactions, get confused and other issues would could constitute a risk for your business and your users. Don’t design for a PC monitor. Make sure your designs are usable on the appropriate size screens and with appropriate space for human digits.

2. Don’t allow users to store their credentials in the app or its underlying data structures. Many mobile phones and such remain woefully unsecured. Even where the vendor has provided for basic security controls for the devices, many users do not use them. Plan ahead for this. The app has to be convenient, but it shouldn’t let the users place undo risk on themselves. If you allow them to store logins, or even a digital certificate, make sure they can’t also store at least 1-2 other pieces of credentials between uses. If someone just picks up their device, they should NOT have access to the users accounts.

3. This goes without saying, but don’t forget encryption. Just because an application uses the cell network, does not mean that you don’t need SSL. (I’m looking at you two developer groups in the last 90 days, you know who you are.) No matter the network, protect your transactions and data streams with strong crypto. The mobile devices can handle it. They can do enough lifting to handle SSL or they shouldn’t be running a banking app. Like Nike says, “Just Do It!”

There you have it. Three basic ways that you can help increase the safety and capability of your financial services app on the iPhone, iPad and other mobile platforms. If you have done these three basics, then you are off to a start. The next crucial step is to get your app and the back-end processes checked via a risk assessment and security test. Give us a call if you need assistance or want us to drop it into our testing lab process. We are seeing quite a few of these days.