Cybersecurity:

Bank and Other Depository Regulators Need Better Data Analytics and Depository Institutions Want More Usable Threat Information

GAO-15-509: Published: Jul 2, 2015. Publicly Released: Jul 2, 2015.

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What GAO Found

Regulators use a risk-based examination approach to oversee the adequacy of information security at depository institutions—banks, thrifts, and credit unions—but could better target future examinations by analyzing deficiencies across institutions. For information technology (IT) examinations, regulators adjust the level of scrutiny at each institution depending on the information they review, past examination results, and any IT changes. GAO reviewed 15 IT examinations and found that regulators generally reviewed institutions' policies, interviewed staff, and examined audits of information security practices. While the largest institutions were generally examined by IT experts, medium and smaller institutions were sometimes reviewed by examiners with little or no IT training. The regulators recognized that some IT training is necessary for all examiners, so each regulator had efforts under way to increase the number of their staff with IT expertise and conduct more training. GAO identified two areas for improvement:

Data analytics. Regulators generally focused on IT systems at individual institutions but most lacked readily available information on deficiencies across the banking system. Although federal internal control standards call for organizations to have relevant, reliable, and timely information on activities, regulators were not routinely collecting IT security incident reports and examination deficiencies and classifying them by category of deficiency. Having such data would better enable regulators to identify and analyze trends across institutions and use that analysis to better target areas for review at institutions.

Oversight authority. Bank regulators directly address the risks posed to their regulated institutions from third-party technology service providers, but the National Credit Union Administration (NCUA) lacks this authority. Cyber risks affecting a depository institution can arise from weaknesses in the security practices of third parties that process information or provide other IT services to the institution. Bank regulators routinely conduct examinations of service providers' information security. Authorizing NCUA to routinely conduct such examinations could help it better ensure that the service providers for credit unions also follow sound information security practices.

Depository institutions obtain cyber threat information from multiple sources, including federal entities such as the Department of the Treasury (Treasury). Representatives from more than 50 financial institutions told GAO that obtaining adequate information on cyber threats from federal sources was challenging. Information viewed as most helpful for assessing threats and protecting systems included details on attacks other institutions experienced. To help address these needs, Treasury has various efforts under way to obtain such information and confidentially share it with other institutions. The department formed a special group that works with other law enforcement and intelligence agencies to obtain declassified information and share it with financial institutions in a series of circulars. Treasury staff also participate in Department of Homeland Security groups that monitor cyber incidents and work with a center that provides cyber threat information to thousands of financial institutions.

Why GAO Did This Study

Depository institutions experienced cyber attacks in recent years that are estimated to have resulted in hundreds of millions of dollars in losses. Depository institution regulators (the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve, the Federal Deposit Insurance Corporation, and NCUA) oversee information security at these institutions and Treasury coordinates protection of the financial sector.

The objectives of this report include examining (1) how regulators oversee institutions' efforts to mitigate cyber threats, and (2) sources of and efforts by agencies to share cyber threat information. GAO collected and analyzed cyber security studies from private-sector sources. GAO reviewed materials from selected IT examinations (based on regulator, institution size, and risk level). GAO also held three forums with more than 50 members of financial institution industry associations who provided opinions on cyber threat information sharing.

What GAO Recommends

Congress should consider granting NCUA authority to examine third-party technology service providers for credit unions. In addition, regulators should explore ways to better collect and analyze data on trends in IT examination findings across institutions. In written comments on a draft of this report, the four regulators stated that they would take steps responsive to this recommendation.

For more information, contact Lawrance Evans, (202) 512-8678, or evansl@gao.gov

Matter for Congressional Consideration

  1. Status: Open

    Comments: In July 2015, we suggested that Congress modify the Federal Credit Union Act to grant NCUA authority to examine technology service providers of credit unions. As of October 2016, Congress had not granted NCUA such authority.

    Matter: To ensure that NCUA has adequate authority to determine the safety and soundness of credit unions, Congress should consider modifying the Federal Credit Union Act to grant NCUA authority to examine technology service providers of credit unions.

Recommendations for Executive Action

  1. Status: Open

    Comments: In July 2015, we recommended that the Office of the Comptroller of the Currency (OCC) and other federal financial institution regulators conduct trend analysis of their IT examination findings to improve their ability to assess the adequacy of information security practices at medium and small institutions. In September 2015, OCC stated that it is taking two actions to respond to our recommendation. First, the agency is integrating the Cybersecurity Assessment Tool (Tool), developed by OCC and other federal financial institution regulators, into OCC's ongoing IT examinations of national banks and federal savings associations. Officials believe that the Tool will provide OCC with a repeatable and measurable process for assessing both the level of risk and the maturity of risk management processes within and across OCC-supervised institutions. Also, officials believe that data gathered in this process will allow OCC to monitor industry trends and identify new or emerging weaknesses where additional guidance or supervisory actions may be needed. Furthermore, the Tool will help OCC allocate examiner resources and better target examiner training. OCC began integrating the Tool in selected examinations in December 2015. Second, OCC stated that it enhanced its guidance and procedures for examiners to identify and aggregate supervisory concerns into matters requiring attention (MRAs), which are the mechanism OCC uses to communicate supervisory concerns to bank management and directors. OCC believes that the enhancements will facilitate systemic categorization of supervisory concerns that strengthen recording, monitoring, and analyzing of volumes and trends across bank portfolios. Also, the enhanced guidance discusses the relationship between MRAs, interagency ratings, OCC's risk assessment system, and enforcement actions. OCC believes that these process enhancements combined with the integration of the Tool, will improve its ability to assess information security practices at medium and small institutions. We will continue to monitor OCC's progress in implementing the Tool and the resulting trend analyses that the Tool is intended to facilitate.

    Recommendation: To improve their ability to assess the adequacy of the information security practices at medium and small institutions, the heads of Federal Deposit Insurance Corporation, the Federal Reserve, Office of the Comptroller of the Currency, and NCUA should routinely categorize IT examination findings and analyze this information to identify trends that can guide areas of review across institutions.

    Agency Affected: Department of the Treasury: Office of the Comptroller of the Currency

  2. Status: Open

    Comments: In July 2015, we recommended that the Federal Deposit Insurance Corporation (FDIC) and other federal financial institution regulators conduct trend analysis of their IT examination findings to improve their ability to assess the adequacy of information security practices at medium and small institutions. As of October 2016, FDIC had not provided an update on its efforts to address this recommendation.

    Recommendation: To improve their ability to assess the adequacy of the information security practices at medium and small institutions, the heads of Federal Deposit Insurance Corporation, the Federal Reserve, Office of the Comptroller of the Currency, and NCUA should routinely categorize IT examination findings and analyze this information to identify trends that can guide areas of review across institutions.

    Agency Affected: Federal Deposit Insurance Corporation

  3. Status: Open

    Comments: In July 2015, we recommended that the Board of Governors of the Federal Reserve System (Board) and other federal financial institution regulators conduct trend analysis of their IT examination findings to improve their ability to assess the adequacy of information security practices at medium and small institutions. As of October 2016, the Board had not provided an update on its efforts to address this recommendation.

    Recommendation: To improve their ability to assess the adequacy of the information security practices at medium and small institutions, the heads of Federal Deposit Insurance Corporation, the Federal Reserve, Office of the Comptroller of the Currency, and NCUA should routinely categorize IT examination findings and analyze this information to identify trends that can guide areas of review across institutions.

    Agency Affected: Federal Reserve System

  4. Status: Open

    Comments: In July 2015, we recommended that the National Credit Union Administration (NCUA) and other federal financial institution regulators conduct trend analysis of their IT examination findings to improve their ability to assess the adequacy of information security practices at medium and small institutions. In July 2016, NCUA told us that it and the other federal financial institution regulators issued the Cybersecurity Assessment Tool (Tool) in June 2015 to provide a comprehensive method for institutions to benchmark their cybersecurity programs. Officials believe that the Tool will allow examiners to consistently and methodically look at credit union risks and trends, as well as collect detailed information on the risks and mitigating controls employed by credit unions. When the Tool is fully implemented, officials expect to be able to aggregate risk indicators and program gaps across the credit union industry to improve resource deployment and enhance cybersecurity supervisory oversight. NCUA plans to begin pilot testing the Tool in late 2016 with program integration targeted for July 2017. We will continue to monitor NCUA's progress with this program and revisit our recommendation in July 2017.

    Recommendation: To improve their ability to assess the adequacy of the information security practices at medium and small institutions, the heads of Federal Deposit Insurance Corporation, the Federal Reserve, Office of the Comptroller of the Currency, and NCUA should routinely categorize IT examination findings and analyze this information to identify trends that can guide areas of review across institutions.

    Agency Affected: National Credit Union Administration

 

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