Tag Archives: Credit Unions

ClawBack For Credit Unions

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I got a question recently from one of our Credit Union clients about ClawBack™. They explained that they don’t really do any internal development, so leaking source code was not a concern for them. Based on that, they wondered, would ClawBack still be a useful tool for them?

I pointed out that most larger Credit Unions do some form of development, or at the very least, that their systems admin folks often write (and potentially expose) scripts and other management tools that would be of use to an attacker. However, even if they didn’t do any development at all, leveraging something like the Professional level of ClawBack as a DIY tool ($149.00 per month) is still a good idea.

Further, I explained that source code leaks are only one third of the focus of the ClawBack tool. It also searches for leaked device/application configurations and leaked credentials. Every Credit Union with a network needs to think about leaked device and application configurations. These are the most commonly found items in ClawBack’s history. Whether by accident, or misunderstanding or malicious intent, thousands of leaked configuration files wind up on the Internet in repositories, support forums, answer sites, social media and paste bins. When found, they can provide significant amounts of damaging information to attackers, ranging from logins and passwords to sensitive cryptography and API keys. In some cases, they can be a nearly complete map of the internal network.

Thirdly, ClawBack also focuses on leaked credentials. It can help identify stolen and compromised passwords belonging to members of your organization. Many times, these credentials contain the same or similar passwords as Internet exposed applications, webmail or email access and potentially even weakly secured VPN instances. Stolen and leaked credentials are among the most significant root causes of breaches, business email compromise and a variety of other fraud.

Your CU Security team can add ClawBack to their toolkit for less than $150 per month. It’s simple to use, flexible and an incredibly powerful capability to minimize the damage from data leaks. Check out this less than 8 minute video for more information. If you’d like to discuss ClawBack or our ClawBack Managed and Professional Services, please drop us a line, or give us a call at (614) 351-1237 today. 

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.

MicroSolved vCISO for Credit Unions

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I recently asked MicroSolved COO, Dave Rose, to share his thoughts with all of us about the vCISO program. He has been leading the effort this last year across several credit unions and regional banks around the US. I asked him for the 3 biggest benefits an organization can expect and here is what he said:

“MicroSolved has been providing vCISO services to Credit Unions for over 20 years. Whether you are a corporate or a natural person CU, hiring MSI for vCISO Services will allow you to:

  • Obtain CISO expertise without having to incur the expense of finding and hiring a CISO. This is an affordable solution that will help keep the risk budget under control.
  • MSI vCISO program comes with the benefit of a focus towards financial expertise and compliance. MSI has had extensive experience working with banks and credit unions on their risk programs, and have spent time educating regulators on risk events and controls.
  • MSI is in the business of mitigating risk. We live it everyday and our clients benefit from that experience. Our clients get to pick the risk work they want resolved and the issues they want remediated. 

You will be hard pressed to find a more efficient and cost effective way to address risk issues and move the regulatory needle. Don’t bear the burden of mitigating risk alone, let MSI be a partner to help you solve your risk needs!”

—Dave Rose

For more information, give us a call at 614-351-1237 or email us at info@microsolved.com. 

Follow Up to Out of Band Authentication Post

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(This is a commentary follow up to my earlier post, located here.)

A couple of folks have commented on Twitter that they have a fear of using SMS for any sort of security operations. There have been discussions about the insecurity of SMS and the lack of attention to protecting the cellular network by carriers around the world. I generally disagree with blanket statements, and I would push for organizations considering SMS as a means of authentication to undertake a real risk assessment of the process before they jump in.
 
However, if the controls in place in the cell networks meet their appetite for risk, then I think it is a perfectly acceptable business case. It certainly beats in-band simple authentication mechanisms like “pictures of trust” and traditional login/password as a security control.
 
At least in SMS authentication, the attacker would usually need to have control over or access to more than one device belonging to the user. I think this helps make the risk model more acceptable for my views.
 
Other folks discussed how Out of Band Authentication (OOBA) has been done now successfully in many places. I agree with this. We know how to do it. There are a LOT of vendors out there who can successfully integrate, deploy and manage a solution for you. Sadly, though, there are still more than a few who are struggling to get it right or done at all. As with most things in life, it helps to do a little research. Organizations should perform due diligence on their vendors and factor vendor risks into the equation of purchases and project planning. 
 
Lastly, a few folks commented on the fact that they, too, are running into speed bumps with deployments and logistics. Several folks echoed the sentiments of the original challenges and few offered suggestions beyond simply “doing more homework” and looking for “quickly scalable solutions”. The good news with this is that you are not alone out there. Other folks are facing AND BEATING challenges. Feel free to reach out to your peers and discuss what is and what isn’t working for them.
 
As per the original post, the more communication and discussion we can have amongst the community about these topics, the better off we all will be. So, discuss, seriously…
 
##Special thanks to the vendors that replied with case studies, references or stories about how they have done integration and deployment. There are a lot of good vendors out there with knowledge in this area. Careful review of their capabilities will help you sort them out from the less capable. Communication is key.
 
Thanks for reading! 

Credit Unions and Small Banks Need Strong Security Relationships

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With all of the attention in the press these days on the large banks, hacking, and a variety of social pressures against the financial institutions, it’s a good time to remember that credit unions and small banks abound around the world, too. They may offer an alternative to the traditional big banking you might be seeking, but they sometimes offer an alternative to the complex, well staffed information security teams that big banks have to bear against attackers and cyber-criminals, too.
 
While this shouldn’t be a worry for you as a consumer (in that your money is secure in a properly licensed and insured institution), it should be a concern for those tasked with protecting the data assets and systems of these organizations.
 
That’s where strong vendor relationships come in. Partnerships with good solution providers, security partners, virtual security teams and monitoring providers can be very helpful when there are a small number of technical resources at the bank or credit union. Ongoing training with organizations like SANS, CUISPA and our State of the Threat series is also very likely to assist the resources they do have in being focused against the current techniques used by attackers. Whether with peers or vendors, relationships are a powerful tool that help security admins in the field.
 
Smaller organizations need to leverage simple, effective and scalable solutions to achieve success. They simply won’t have the manpower to manage overwhelming alerts, too many log entries or some of the other basic mechanisms of infosec. They either must invest in automation or strategically outsource some of those high resource functions to get them done. If your bank has a single IT person who installs systems, manages software, secures the network, helps users, and never goes on vacation; you have one overwhelmed technician. Unfortunately, this all too common. Even worse is that many times, the things that can’t be easily done sometimes end up forgotten, pushed off or simply ignored. 
 
In some cases, where some of the security balls may have been dropped, attackers take advantage. They use malware, bots, social engineering and other techniques to scout out a foothold and go to work on committing fraud. That’s a bad way to learn the lessons of creating better security solutions.
 
So, the bottom line is if you are one of these smaller organizations, or one of the single technicians in question, you need to find some relationships. I suggest you start with your peers, work with some groups in your area (ISSA, ISACA, ISC2, etc.) and get together with some trusted vendors who can help you. Better to get your ducks in a row ahead of time than to have your ducks in the fire when attackers come looking for trouble. 

Know Who’s Out to Hack Your Credit Union

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One of the biggest questions we get when we talk to Credit Unions is about threats. They often want to know who might be targeting Credit Unions and how they might get attacked. Based on these questions and how often we hear them, we have come up with a way for you to actually get some metrics and intelligence around your own threat postures.
 
I am proud to introduce a new short-term service for Credit Unions that leverages our patent-pending HoneyPoint technology in a useful, powerful, easy and affordable way.  The MSI Threat Posture Analysis is a new service that does just that. The service is comprised of the following phases:
 
1. Initial consultation – our teams work together to plan for a quick, safe and easy deployment of our HoneyPoint technology; this initial discussion helps us decide if we are going to leverage a HoneyPoint hardware, software or combined deployment and exactly what we want to emulate for metrics gathering; the length of the metrics gathering mission is also determined (usually 90 days).
 
2. Pricing and contracts – based on our work together, fixed bid pricing is provided for the analysis and monitoring.
 
3. Delivery of technology – our teams work together to deliver and install the technology; MSI monitors the deployment remotely back at our NOC.
 
4. Analysis – MSI performs analysis of the data gathered; generating a set of reports that details sources of attacks, general estimated capabilities, attack frequency and other metrics designed to feed real world threat data into the Credit Union’s information security program.
 
5. Decommission and return of the technology – our teams work together to uninstall the technology and return any hardware to MSI. 
 
6. Follow on Q&A – for 3 months, MSI will continue to be available to answer questions or discuss the data and metrics identified in the analysis.
 
It’s that easy. You can quickly, easily, safely and affordably, move from blunt estimations of threats to real world data and intelligence. If you would like that intelligence as an ongoing basis, give us a call and we can discuss our managed services with you as well. 
 
So, if you’re tired of doing risk assessments without real numbers to back up your data or if your team has hit the maturity point where they can use real world metrics and threat source data to create firewall rules, black holes and other dynamic defenses, this approach can give them the data they are hungry for.
 
If you would like to discuss the analysis or hear more about it, give your account executive a call or reach out to me on Twitter (@lbhuston). I look forward to talking with you about the successes we are seeing.
 
As always, thanks for reading and stay safe out there!

MSI Strategy & Tactics Talk Ep. 15: Information Security for Credit Unions

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Credit Unions have become popular over the past few weeks as societal trends have placed greater pressure on bank policies. What’s the scoop on Credit Unions and information security? Take a listen! Discussion questions include:

  • Supporting Credit Union swap through infosec
  • The “hactivist” group Anonymous and “Dump Your Bank Day”
  • Is infosec strong at Credit Unions?
  • Our approaching toward testing Credit Unions and banking apps

Panelists:
Brent Huston, CEO, Founder, and Security Evangelist
Adam Hostetler, Network Engineer and Security Analyst
Phil Grimes, Security Analyst
John Davis, Risk Management Engineer
Mary Rose Maguire, Marketing Communication Specialist and moderator

Click the embedded player to listen. Or click this link to access downloads. Stay safe!