A.
Operating Environment |
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| 1. |
Review
the process in place to ensure the system inventories remain accurate
and reflect the complete enterprise, including:
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Computer
equipment (mainframes, midranges, servers, and standalone): |
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Vendor,
model and type; |
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Operating
system and release/version; |
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Processor
capability (millions of instructions per second [MIPS], etc.); |
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Memory; |
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Attached
storage; |
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Role; |
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Location,
IP address where applicable, and status (operational/not operational);
and |
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Application
processing mode or context. |
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Network
devices: |
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Vendor,
model, and type; |
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IP
address; |
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Native
storage (random access memory); |
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Hardware
revision level; |
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Operating
systems; and |
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Release/version/patch
level. |
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Software: |
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Type
or application name; |
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Manufacturer
and vendor; |
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Serial
number; |
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Version
level; |
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Patch
level; and |
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Number
of licenses owned and copies installed. |
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B.
Controls Policies, Procedures and Practices |
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| 1. |
Determine
if supervisory personnel review the console log and retain it in
safe storage for a reasonable amount of time to provide for an audit
trail.
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C.
Storage/Back-Up |
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| 1. |
Determine
if management has processes to monitor and control data storage.
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| 2. |
If
the institution has implemented advanced data storage solutions,
such as storage area network (SAN) or network-attached storage (NAS):
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Ensure
management has appropriately documented its cost/benefit analysis
and has conclusively justified its use. |
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Review
the implemented storage options and architectures for critical applications
to ensure they are suitable and effective.
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Ensure
data storage administrators manage storage from the perspective
of the individual applications, so that storage monitoring and problem
resolution addresses the unique issues of the specific business
lines. |
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| 3. |
If
a tape management system is in use, verify that only appropriate
personnel are able to override its controls.
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| 4. |
Determine
if management has adequate off-site storage of:
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Operations
procedures manuals; |
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Shift
production sheets and logs; and |
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Run
instructions for corresponding shift production sheets. |
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D.
Environmental Monitoring and Control |
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| 1. |
Assess
whether the identified environmental controls and monitoring capabilities
can detect and prevent disruptions to the operations environment
and determine whether:
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Sufficient
back-up electrical power is available (e.g. separate power feed,
UPS, generator); |
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Sufficient
back-up telecommunications feeds are available; |
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HVAC
systems are adequate and can operate using the back-up power source; |
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Computer
cabling is documented, organized, labeled, and protected; |
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The
operations center is equipped with an adequate smoke detection and
fire suppression system and if it is designed to minimize or prevent
damage to computer equipment if activated; |
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Appropriate
systems have been installed for detecting and draining water leaks
before equipment is damaged; |
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Management
schedules and performs preventive maintenance in a reliable and
secure manner that minimizes disruption to the operating environment;
and |
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Employee
training for the use of various monitoring and control systems is
adequate. |
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E.
Physical Security |
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| 1. |
Review
and determine whether the identified physical security measures
are sufficient to reasonably protect the operations center’s
human, physical, and information assets. Consider whether:
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The
operations center is housed in a sound building with limited numbers
of windows and external access points; |
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Security
measures are deployed in a zoned and layered manner; |
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Management
appropriately trains employees regarding security policies and procedures; |
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Perimeter
if securities measures (e.g. exterior lighting, gates, fences, and
video surveillance) are adequate; |
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Doors
and other entrances are secured with mechanical or electronic locks; |
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Guards
(armed or unarmed) are present. Also determine if they are adequately
trained, licensed, and subjected to background checks; |
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There
are adequate physical access controls that only allow employees
access to areas necessary to perform their job; |
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Management
requires picture ID badges to gain access to restricted areas. Determine
whether more sophisticated electronic access control devices exist
or are necessary; |
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Management
adequately controls and supervises visitor access through the use
of temporary identification badges or visitor escorts; |
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Doors,
windows, and other entrances and exits are equipped with alarms
that notify appropriate personnel in the event of a breach and whether
the institution uses internal video surveillance and recording; |
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Personnel
inventory, label, and secure equipment; |
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Written
procedures for approving and logging the receipt and removal of
equipment from the premises are adequate; |
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Confidential
documents are shredded prior to disposal; and |
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Written
procedures for preventing information assets from being removed
from the facility are adequate.
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F.
Event/Problem Management |
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| 1. |
Determine
whether there is adequate documentation to support a sound event/management
program, including:
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Problem
resolution logs; |
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Logs
indicating personnel are following requirements in operations procedures
manual(s); |
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Problem
resolution notifications to other departments; |
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Training
records indicating operations personnel training for: |
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Business
continuity event escalation procedures; |
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Security
event escalation procedures; and |
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Unusual
activity resolution procedures. |
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Historical
records of: |
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Business
continuity event escalation; |
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Security
event escalation; and |
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Unusual
activity event and corresponding resolution. |
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| 2. |
Determine
whether there is adequate documentation to support a sound event/management
program, including:
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Personnel
evacuation; |
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Shutting
off utilities; |
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Powering
down equipment; |
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Activating
and deactivating fire suppression equipment; and |
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Securing
valuable assets. |
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| 3. |
Determine
whether emergency procedures are posted throughout the institution.
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| 4. |
Assess
whether employees are familiar with their duties and responsibilities
in an emergency situation and whether an adequate employee training
program has been implemented.
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| 5. |
Determine
if the institution periodically conducts drills to test emergency
procedures.
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G.
Help Desk/User Support Processes |
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| 1. |
Evaluate
whether MIS is appropriate for the size and complexity of the institution.
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Determine
whether effective an MIS is in place to monitor the volume and trend
in key metrics, missed SLAs, impact analysis, root cause analysis,
and action plans for unresolved issues. |
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Assess
whether action plans identify responsible parties and time frames
for corrective action; |
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| 2. |
Determine
if the technology used to manage help desk operations is commensurate
with the size and complexity of the operations. Consider:
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Help desk access; |
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Logging and monitoring of issues; |
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Automated event/problem logging and tracking process
for issues that cannot be resolved immediately; and |
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Automated alerts when issues are in danger of not being
resolved within the SLA requirements, or alternatively, the effectiveness
of the manual tracking processes. |
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| 3. |
Determine
whether user authentication practices are commensurate with the
level of risk and whether the types of authentication controls used
by the help desk are commensurate with activities performed.
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| 4. |
Determine
whether the quality of MIS used to manage help desk operations is
commensurate with the size and complexity of the institution. Consider
the need for metrics to monitor issue volume trends, compliance
with SLA requirements, employee attrition rates, and user satisfaction
rates.
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| 5. |
Determine
whether the institution uses risk-based factors to prioritize issues.
Identify how the institution assigns severity ratings and prioritizations
to issues received by the call center.
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| 6. |
Assess
management’s effectiveness in using help desk information
to improve overall operations performance.
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Identify
whether management has effective tools and processes in place to
effectively identify systemic or high-risk issues. |
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Determine
whether management identifies systemic or high-risk issues and whether
it has an effective process in place to address these issues. Effective
processes would include impact and root cause analysis, effective
action plans, and monitoring processes. |
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H.
Items Processing |
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| 1. |
Determine
if there are adequate controls around transaction initiation and
data entry, including:
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Daily
log review by the supervisor including appropriate sign-off; |
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Control
over and disposal of all computer output (printouts, microfiche,
optical disks, etc.); |
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Separation
of duties; |
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Limiting
operation of equipment to personnel who do not perform conflicting
duties; |
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Balancing
of proof totals to bank transmittals; |
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Maintaining
a log of cash letter balances for each institution; |
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Analyzing
out-of-balance proof transactions to determine if personnel identify
discrepancies and adjust and document them on proof department correction
forms. Also determine if the supervisor approves the forms; |
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Balancing
cash letter totals to the cash letter recap; and |
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Daily
management review of operation reports from the shift supervisors. |
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| 2. |
Determine
if the controls around in-clearings are adequate, including:
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Courier
receipt logs completion; |
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Approval
of general ledger tickets by a supervisor or lead clerk; |
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Input
and reporting of captured items in a system-generated report with
totals balanced to the in-clearing cash letter; |
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Analyzing
and correcting rejected items; |
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Logging
of suspense items sent to the originating institution for resolution; |
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Approval
of suspense items by a supervisor; |
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Timely
transmission of the capture files; and |
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Captured
paid items that are securely maintained or returned to the client. |
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| 3. |
Determine
if there are adequate controls for exception processing, including:
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Adequate
and timely review of exception and management reports including
supporting documentation; |
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Accounting
for exception reports from client institutions; |
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Verification
of client totals of return items to item processing site totals; |
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Prior
approval for items to be paid and sent to the proof department for
processing; |
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Accounting
and physical controls for return item cash letters and return items
being sent to Federal Reserve or other clearinghouse; and |
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Filming
of return item cash letters and return items prior to being shipped
to the Federal Reserve or other clearinghouse. |
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| 4. |
Determine
the adequacy of controls for statement processing, including:
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Logging
and investigation of unresolved discrepancies; and |
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Supervisor
review of the discrepancy log. |
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I.
Imaging Systems |
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| 1. |
Review
and evaluate the imaging system. Determine:
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How
the system communicates with the host; |
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The
system’s capacity and future growth capability; |
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Whether
the topology is based on a mainframe, midrange, or PC; |
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The
vendor; |
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The
imaging standard being used; and |
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The
document conversion process. |
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| 2. |
Review
and evaluate back-up and recovery procedures.
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| 3. |
Review
and evaluate the procedures used to recover bad images. Does it
re-scan all or re-scan only defective images
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| 4. |
Review
and evaluate the process and controls over document indexing. Does
the system index documents after each one is scanned or after all
documents are scanned
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| 5. |
Review
and evaluate whether imaging hardware and software are interchangeable
with that of other vendors. If they are, does management utilize
normal processes or procedures when making changes or repairs? If
they are not, has management identified alternate solutions should
the current imaging hardware and software become unavailabl
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| 6. |
Review
and evaluate the access security controls, with particular attention
to the following:
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Data
security administrator access; |
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Controls
over electronic image files; |
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Controls
over the image index to prevent over-writing an image, altering
of images, or insertion of fraudulent images; |
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Controls
over the index file to prevent the file from being tampered with
or damaged; and |
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Encryption
of image files on production disks and on back-up media. |