All About FINRA Risk Assessments

FINRA (Financial Industry Regulatory Authority) requires an enterprise risk assessment once per year for all member firms. This risk assessment should be completed using the NIST Cyber-Security Framework, if appropriate for the size of the organization. At MSI, we fully embrace the NIST framework and use it routinely for our approach to information security and risk management.

Who Performs the FINRA Risk Assessment?

The FINRA requirements for risk assessment include that it be completed by independent third-party assessors, if possible, or otherwise by internal information security experts (if qualified and available). MSI’s approach is to work WITH our client’s internal team members, including them in the process, and leveraging their deep knowledge of the firm’s operations, while still maintaining our independence. In our experience, this provides the best return on investment for the risk assessment, and allows granular analysis without draining critical internal client resources.

What Analysis Does the FINRA Risk Assessment Require?

Each FINRA risk assessment should include an inventory of all critical data, PII and other sensitive information. Then, each asset should be reviewed for its impact on the business and identification of relevant controls, risks, mitigations and residual risks should occur. This process requires deeper knowledge of cyber security than most firms are comfortable with, and the experience and attention to detail of the assessor can make or break the value of the assessment.

Is the FINRA Risk Assessment Affordable?

Since the workload of a risk assessment varies greatly based on the size and complexity of the organization being assessed, smaller firms are naturally more affordable than larger firms. Risk assessments are affordable for nearly every firm today, and the work plans can be easily customized to fit even the tightest of budgets. In addition, when working with experienced and knowledgable assessors, the cost can be even lower and the results even more valuable. At MSI, our assessment team has more than 15 years of experience, across a wide variety of size, type and operational styles of client firms. You won’t find any “on the job training” here, our experts are among the best and most recognized in the world. We are excellent at what we do, and we can help your firm get the best ROI on a risk assessment in the industry.

How Do I Get Started on a FINRA Risk Assessment from MSI?

Simply drop us a line via this web form, or give us a call at (614) 351-1237 to arrange for a free, no hassle call with our team. We’ll explain how our process works, gather some basic information and provide you with a proposal. We’d love the chance to talk with you, and be of service to your firm. At MSI, we build long-term client relationships and we truly want to partner to help your firm be more successful, safer and manage the risks of the online world more easily. Give us a call today! 

Coming to Grips with DDoS – Response

In our first two blogs concerning Distributed Denial of Service (DDoS) attacks and small service industries, we presented measures organizations can take to prepare for and defend against DDoS attacks. In this final installment on the subject, we will discuss methods of response to these incidents.

The first thing to do when you think you are under DDoS attack is to not panic. Calm and considered responses are always more effective than immediately jumping in and possibly cutting off legitimate connection requests. An ill-considered response on your part could cause the very denial of service your attacker intended in the first place. The best thing you can do is to immediately access your incident response plans and begin to implement those pre-planned procedures you worked so hard on. We are constantly amazed at how many organizations fail to follow their own response planning in the heat of a real incident! 

The next step in the process is traffic (log) analysis. You need to be able to identify what type of attack is being perpetrated and the kinds of bogus requests that are being made. This is where large log capacities and log aggregation tools come in very handy. Being able to view a large amount of data from a central console truly helps you recognize patterns in the attack. Since application layer attacks that employ IP spoofing are presently being used, pattern and type recognition are often the only means you have to discern good traffic from bad.

Once you are able to get a handle on what the bad traffic looks like, you can start filtering it out. This is best done by appliances as close to the network edge as possible. You can also work with your ISP which may be able to assist with filtering as well as other mechanisms such as rate and connection limiting.

After the attack is under control, don’t forget to work with law enforcement agencies such as the FBI and US-CERT. They are interested in these events and may be able to assist you in finding and dealing with the perpetrators. Reporting incidents is important because it is crucial to know the number and types of DDoS attacks that are really taking place out there in order to effectively respond to them. Reporting ends up being good for everybody!

Finally, it is very important to conduct lessons learned meetings and to adjust your incident response and business continuity planning. Table top exercises and other incident preparation techniques are helpful, but nothing helps you learn the hard lessons like a real incident. Why waste the only valuable thing to come out of the whole mess!

This series is written by John Davis, MicroSolved, Inc.

Coming to Grips with DDoS – Prepare

This post introduces a 3 part series we are doing covering distributed denial of service attacks (DDoS) and helping organizations prepare for them. The series will cover 3 parts, Prepare, Defend and Respond. 

Part 1 of 3 – Prepare.

Distributed Denial of Service (DDoS) attacks use networks of compromised computers (botnets) or web servers (brobots) to flood organization websites with so much traffic that it causes them to fail. This is especially worrying for financial institutions and utilities which rely so very heavily on the availability of their services and controls. DDoS attacks are also mounted by attackers to hide fraud or other hacking activities being perpetrated on networks. Although these types of attacks are not new, they are presently increasing in frequency and especially in sophistication. Application layer DDoS attacks do a good job of mimicking normal network traffic and recent DDoS attacks have been measured at a huge 65 Gb (nearly 10 times the previous high point). The purpose of this blog is to discuss some methods small organizations can employ to properly prepare for DDoS attacks. (Later articles in this series will discuss means for defending against and responding to these attacks).

The first thing any organization should do in this effort is proper pre-planning. Ensure that DDoS is included in your risk assessment and controls planning efforts. Include reacting to these attacks in your incident response and business continuity plans. And as with all such plans, conduct practice exercises and adjust your plans according to their results. In all our years in business, MSI has never participated in a table top incident responce or disaster recovery exercise that didn’t expose planning flaws and produce valuable lessons learned.

Next, your organization should consider DDoS when choosing an ISP. It helps immensely to have an Internet provider that has enough resources and expertise to properly assist if your organization is targeted for one of these attacks. Ensure that you develop a close relationship with your ISP too – communicate your needs and expectations clearly, and find out from them exactly what their capabilities and services really are. 

Finally on the preparation side of the problem, make sure that you keep well informed about DDoS and the actual threat level it poses to your organization. Keep active in user groups and professional organizations. Use the net to gather intelligence. The Financial Service Information Sharing and Analysis Center (FS-ISAC) has plenty of useful and up to date information on DDoS. You can even turn the World Wide Web against the enemy and use it to gather intelligence on them!

–This article series is written by John Davis of MSI. 

PS – This is NOT a problem you can “purchase your way out” of. Organizations can’t and should not buy huge amounts of bandwidth as a preparation for DDoS. The cost impacts of such purchases are not effective, nor is bandwidth size an effective control in most cases. Note that some technology solutions for packet scrubbing and the like do exist. Your milage may vary with these solutions. MSI has not reviewed or tested any of the DDoS technology products as a part of this series.

Three Tips for Banking App Dev for Mobile Devices

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.