How familiar is your team with the FFIEC IT Examination Handbook?
We use the FFIEC IT Examination Handbook as a working reference when we plan IT controls and security posture for our bank clients — the same way a generalist who works with banks pays attention to FFIEC guidance. We're not the auditor, and we're not positioning ourselves as FFIEC certified examiners. What we are is the IT and security team that works alongside your internal compliance officer (or your bank's audit firm) to make sure the IT side of the program lines up with what those professionals expect to see.
Have you been on-site during a bank or credit-union examination?
Yes — for NCUA examinations at Arkansas credit unions. In that role we sit in the examination room, answer IT-control questions in real time, walk examiners through firewall configuration, MFA, monitoring, patch management, and backup-recovery systems, and produce the documented evidence on demand. The role is part interpreter (translating what the examiner is asking into what your team needs to demonstrate) and part proof-keeper (making sure the documentation is current, signed, dated, and in the right format).
Do you sign formal Business Associate / Information Security Program agreements with banks?
Yes. We sign Information Security Program (ISP) agreements, Outsourced Service Provider (OSP) agreements, and (where applicable) HIPAA Business Associate Agreements with our bank clients — the formal vendor-management paperwork the FFIEC and NCUA expect any service provider with access to customer data to execute. Many generic MSPs refuse to sign these because of the liability exposure. We sign them because doing the work right means accepting the accountability that comes with it.
How do you handle core-processor changeovers (Jack Henry, Fiserv, FIS)?
Core-processor migration is one of the highest-risk projects a community bank takes on — it touches every workflow, every reconciliation, every customer-facing system. We work alongside your core-processor implementation team on the IT side: network and bandwidth sizing, firewall rule updates, identity federation, certificate management, cutover testing, parallel-run validation, rollback planning, and the documentation the examiner will eventually want to see explaining why the new environment is at least as secure as the old one. We don't replace your core processor's project team — we make sure the IT pieces they don't own are ready when they need them.
Can you support both small community banks AND credit unions?
Yes. The two share most of the same IT security work — the regulatory framework differs (FDIC/OCC vs NCUA) but the underlying examination handbook content is largely parallel. Credit unions are governed by NCUA Part 748 Appendix A (the Guidelines for Safeguarding Member Information) which closely mirrors the FFIEC framework. We've done both — the engagement structure is the same; the citations on the gap-assessment report differ.
What's your approach to ACH and wire fraud prevention beyond just turning on positive pay?
Positive pay and account validation are the table stakes — they catch the obvious stuff. The real work is layered: dual-control approval workflows on outgoing wires, callback verification on first-time payees and amount-threshold changes, behavioral baselining (a $50K wire from an account that normally moves $5K triggers manual review), email-impersonation defenses on the operations team's inboxes (BEC fraud almost always starts with a spoofed email from "the CFO" or "the auditor"), and tabletop drills with your operations team so the front line knows what a fraudulent request looks like before it's an actual loss event.
How do you handle the board-of-directors IT and cybersecurity reporting requirement?
Both FFIEC and NCUA expect the board to receive regular, substantive IT and cybersecurity updates — not just "IT is fine." We produce board-level reports on the cadence your bank already uses, covering security posture, incident log (even minor events), patch compliance, MFA enrollment, training-completion rates, vendor-management status, BCP/DR test results, and material changes to the threat landscape. The reports are written so a non-technical board member can read them, and so an examiner reviewing a multi-year run can see real maturation of the program.
What's your team's role versus our internal IT staff during an examination?
It depends on what you have in-house. If you have an internal IT or compliance officer running the program, we're the specialist backup: we handle the technical evidence requests, configuration walkthroughs, and the deeper FFIEC-handbook citations your generalist staff isn't expected to know cold. If you don't have an internal IT lead, we run point — coordinating the examination preparation, owning the evidence binder, and being the primary contact for the IT portion of the examination. Either model works. The examiner cares that the work gets done correctly, not who does it.