IT Controls & GLBA Compliance Program
Transforming Regulatory Pressure into Operational Excellence
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Examination Findings Threatening Operational Authority
This mid-sized financial institution received significant examination findings related to IT general controls and GLBA privacy requirements. The findings weren't just compliance checkboxes—they represented fundamental weaknesses in how the organization protected customer information.
Regulators had issued a matter requiring attention (MRA) with specific remediation deadlines. Leadership faced the prospect of enforcement action if they couldn't demonstrate meaningful progress. Internal resources lacked the specialized expertise to develop comprehensive remediation plans.
The pressure extended beyond regulatory relationships. Customer trust, board confidence, and employee morale all suffered as the organization struggled to respond. They needed external expertise that could both satisfy regulators and genuinely improve their security posture.
Engagement Focus Areas
Structured Remediation with Sustainable Controls
I began with a detailed scoring assessment against GLBA Safeguards Rule requirements, establishing a clear baseline and identifying specific control gaps. This quantified approach provided regulators with measurable progress indicators.
Risk identification went beyond the examination findings to uncover related vulnerabilities that could generate future findings. I developed remediation plans that addressed root causes rather than just symptoms, building controls that would prevent recurrence.
Program development created sustainable governance structures. Policies were rewritten with clear ownership and review cycles. Control testing procedures were established to provide ongoing assurance. Board reporting frameworks were enhanced to demonstrate oversight.
My regulatory summarization work helped leadership communicate effectively with examiners, translating technical remediation into language that demonstrated both progress and commitment to sustained improvement.
Key Outcomes
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