March 4, 2001
FYI - On February 23, 2001, Comptroller Hawke Notes Promise, Risks of Internet Banking.
FYI - On February 26, 2001, The Federal Deposit Insurance Corporation (FDIC) named five agency veterans to key positions within its Bank Technology Group (BTG).
FYI - On March 2, 2001, Federal Deposit Insurance Corporation (FDIC) Inspector General Gaston L. Gianni, Jr., announced today that former FDIC employee Theresa A. Hill of Seat Pleasant, MD, pled guilty on March 1 to conspiracy in connection with an identity fraud scheme.
INTERNET COMPLIANCE - Reserve Requirements of Depository Institutions (Regulation D)
Pursuant to the withdrawal and transfer restrictions imposed on savings deposits, electronic transfers, electronic withdrawals (paid electronically) or payments to third parties initiated by a depositor from a personal computer are included as a type of transfer subject to the six transaction limit imposed on passbook savings and MMDA accounts.
Institutions also should note that, to the extent stored value or other electronic money represents a demand deposit or transaction account, the provisions of Regulation D would apply to such obligations.
Consumer Leasing Act (Regulation M)
The regulation provides examples of advertisements that clarify the definition of an advertisement under Regulation M. The term advertisement includes messages inviting, offering, or otherwise generally announcing to prospective customers the availability of consumer leases, whether in visual, oral, print, or electronic media. Included in the examples are
on-line messages, such as those on the Internet. Therefore, such messages are subject to the general advertising requirements.
INTERNET SECURITY - We continue our review of the FDIC paper "Risk Assessment Tools and Practices or Information System Security."
INTRUSION DETECTION SYSTEMS
Vulnerability assessments and penetration analyses help ensure that appropriate security precautions have been implemented and that system security configurations are appropriate. The next step is to monitor the system for intrusions and unusual activities. Intrusion detection systems (IDS) may be useful because they act as a burglar alarm, reporting potential intrusions to appropriate personnel. By analyzing the information generated by the systems being guarded, IDS help determine if necessary safeguards are in place and are protecting the system as intended. In addition, they can be configured to automatically respond to intrusions.
Computer system components or applications can generate detailed, lengthy logs or audit trails that system administrators can manually review for unusual events. IDS automate the review of logs and audit data, which increases the reviews' overall efficiency by reducing costs and the time and level of skill necessary to review the logs.
Typically, there are three components to an IDS. First is an agent, which is the component that actually collects the information. Second is a manager, which processes the information collected by the agents. Third is a console, which allows authorized information systems personnel to remotely install and upgrade agents, define intrusion detection scenarios across agents, and track intrusions as they occur. Depending on the complexity of the IDS, there can be multiple agent and manager components.
Generally, IDS products use three different methods to detect intrusions. First, they can look for identified attack signatures, which are streams or patterns of data previously identified as an attack. Second, they can look for system misuse such as unauthorized attempts to access files or disallowed traffic inside the firewall. Third, they can look for activities that are different from the users or systems normal pattern. These "anomaly-based" products (which use artificial intelligence) are designed to detect subtle changes or new attack patterns, and then notify appropriate personnel that an intrusion may be occurring. Some anomaly-based products are created to update normal use patterns on a regular basis. Poorly designed anomaly-based products can trigger frequent false-positive responses.
Although IDS may be an integral part of an institutions overall system security, they will not protect a system from previously unknown threats or vulnerabilities. They are not self-sufficient and do not compensate for weak authentication procedures (e.g., when an intruder already knows a password to access the system). Also, IDS often have overlapping features with other security products, such as firewalls. IDS provide additional protections by helping to determine if the firewall programs are working properly and by helping to detect internal abuses. Both firewalls and IDS need to be properly configured and updated to combat new types of attacks. In addition, management should be aware that the state of these products is highly dynamic and IDS capabilities are evolving.
IDS tools can generate both technical and management reports, including text, charts, and graphs. The IDS reports can provide background information on the type of attack and recommend courses of action. When an intrusion is detected, the IDS can automatically begin to collect additional information on the attacker, which may be needed later for documentation purposes.
Please remember that we perform vulnerability testing and would be happy to e-mail the financial institution a proposal. Please send an e-mail to Kinney Williams at
email@example.com for more information.