Eric Vuilliomenet, Associate of (ISC)2, Security+, Network+ Examiner; NCUA Region IV NCUA Examination Update
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1 Eric Vuilliomenet, Associate of (ISC)2, Security+, Network+ Examiner; NCUA Region IV NCUA Examination Update October 19, 2017
2 Agenda Hot Topics MLA SCRA EOCA RR 748 Disaster Recovery InfoSec Risk Assessment FFIEC CAT
3 MLA What is it? Military Lending Act MAPR 36% limit Who is covered? Ac6ve duty servicemember and dependent(s) What is the NCUA looking for? Sound administra6on Iden6fica6on of covered borrowers Mandatory loan disclosures
4 MLA - Exercise Scenario: A servicemember and member of your credit union applies for a credit card with a $2,400 limit. The advervsed rate is 15% for that product. The member wants to purchase loan protecvon (life, disability, unemployment, and family leave) at a cost of $500. Can you offer that credit card under these condi6ons?
5 What is it? SCRA Servicemember Civil Relief Act Reduc6on to not more than 6% No ac6on (foreclosure, seizure, evic6on) allowed without court order Who is covered? Servicemember in ac6ve duty and dependent(s) What is the NCUA looking for? Sound administra6on Compliant applicable loans
6 EOCA What is it? Equal Opportunity Credit Act Prohibited bases What is the NCUA looking for? Policy Training Loan policy excep6on tracking Independent periodic review
7 RR 748 Information Security InfoSec Program FFIEC CAT Disaster Recovery Plan
8 InfoSec Program What is the NCUA looking for? Informa6on Security policy Risk Assessment Tes6ng Training Incident response Annual repor6ng
9 InfoSec Program - Exercise We assessed the PII stored in our desktops high risk. Our branch is isolated from the rest of town, and poor lighvng around the area increases the chances of burglary. There has been various burglaries around town in the past 12 months. Losing that sensivve member data would significantly impact our reputavon, and pressure us to offer credit monitoring services which could be costly. To mivgate this risk, we have encrypted all of our hard drives, and installed a security alarm and camera system. Is this an acceptable risk assessment?
10 What is it? FFIEC CAT Federal Financial Ins6tu6ons Examina6on Council Cybersecurity Assessment Tool Mul6-domain risk profile assessment Not the InfoSec risk assessment What is the NCUA looking for? Currently voluntary
11 Disaster Recovery Plan What is the NCUA looking for? Risk Assessment Threat, impact, and alterna6ve recovery strategies Policy Annual training Annual tes6ng Facility Data Backup
12 Conclusion SCRA, MLA, and EOCA: Sound policies and procedures are in place. Covered transac6ons are compliant. InfoSec: RR 748-required elements exist. FFIEC CAT: Voluntary. Disaster Recovery Plan: At least a risk assessment, policy, training, and tes6ng.
13 References RR Part 748: Informa6on Security RR Part 749: Disaster Recovery LTR 01-CU-21: Disaster Recovery LTR 09-CU-12: SCRA Regulatory Alert 16-RA-04: MLA Fair Lending Guide 2017: ECOA
14 Questions? NCUA Examination Update 14
15 OfHice Contact Page Feel free to contact our office with quesvons or comments. Staff: Eric Vuilliomenet, Examiner Region IV Office: (512) NCUA Examination Update 15
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