Disaster Recovery White Papers

Legislation Affecting Bank Security: Ensuring Integrity and Trustworthiness of Electronic Data in Compliance with GLB/OCC Requirements

• Tags:
• disaster recovery,
• states,
• compliance,
• comply

Overview The prevalence of Internet-based banking, as well as the electronic infrastructures now underlying even conventional banking, make computer and data security mandatory in the financial services industry.

The Gramm-Leach-Bliley Act (GLB), signed into law in November 1999, is one federal response to the implications of online banking, ecommerce, electronic records and the need to keep customer records secure. GLB requires banks to protect customer privacy and prove it. Together, the requirements for security and privacy converge to position network and data integrity—and the ability to remediate quickly— as the foundation of a bank's IT policies and procedures.

In conjunction with moves to implement GLB, the Office of the Comptroller of the Currency (OCC) has published bulletins1 providing guidance to national banks on how to prevent, detect and respond to intrusions into their computer systems. The OCC's jurisdiction is to charter, regulate, and supervise national banks to ensure a safe, sound, and competitive banking system that supports the citizens, communities, and economy of the United States. The OCC charters, regulates and examines approximately 2,600 national banks and 66 federal branches and agencies of foreign banks in the United States, accounting for 58 percent of the nation's banking assets.

Failure to comply with OCC guidelines for GLB compliance is not a trivial issue. It can shut a bank down. There is the time lost in actual system downtime due to intrusion, time spent finding and repairing the damage, plus OCC-required shutdown until compliance and remediation are demonstrated to their satisfaction. In addition, OCC has the authority to levy fines and/or suspend a bank's charter for failure to comply.

Real-time intrusion detection and response mechanisms are key to the OCC's recommendations, which cover the gamut from basic security procedures such as employee background checks, to technology-based strategies suc

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