September 17, 2000
FYI - The 7 Top Management Errors that Lead to Computer Security Vulnerabilities
FYI - First Virginia Banks' customer representatives got an earful from people complaining that they were seeing other people's banking information in their online accounts summaries.
INTERNET SECURITY - We continue our review of the OCC Bulletin about Infrastructure Threats and Intrusion Risks. This week we review part two of three regarding controls to prevent and detect intrusions.
4) Attack Profile. Frequently systems are installed with more available components and services than are required for the performance of necessary functions. Banks maintaining unused features may unwittingly enable network penetration by increasing the potential vulnerabilities. To reduce the risk of intrusion, institutions should use the minimum number of system components and services to perform the necessary functions.
5) Modem Sweep. While access to a system is typically directed through a firewall, sometimes modems are attached to the system directly, perhaps without the knowledge of personnel responsible for security. Those modems can provide an uncontrolled and unmonitored area for attack. Modems that present such vulnerabilities should be identified and either eliminated, or monitored and controlled.
6) Intrusion Identification. Real-time identification of an attack is essential to minimize damage. Therefore, management should consider the use of real-time intrusion detection software. Generally, this software inspects for patterns or "signatures" that represent known intrusion techniques or unusual system activities. It may not be effective against new attack methods or modified attack patterns. The quality of the software and sophistication of an attack also may reduce the software's effectiveness. To identify intrusions that escape software detection, other practices may be necessary. For example, banks can perform visual examinations and observations of systems and logs for unexpected or unusual activities and behaviors as well as manual examinations of hardware. Since intrusion detection software itself is subject to compromise, banks should take steps to ensure the integrity of the software before it is used.
7) Firewalls. Firewalls are an important component of network security and can be effective in reducing the risk of a successful attack. The effectiveness of a firewall, however, is dependent on its design and implementation. Because misconfigurations, operating flaws, and the means of attack may render firewalls ineffective, management should consider additional security behind the firewall, such as intrusion identification
INTERNET COMPLIANCE -Truth in Savings Act (Regulation DD)
Financial institutions that advertise deposit products and services on-line must verify that proper advertising disclosures are made in accordance with all provisions of the regulations. Institutions should note that the disclosure exemption for electronic media does not specifically address commercial messages made through an institution's web site or other on-line banking system. Accordingly, adherence to all of the advertising disclosure requirements is required.
Advertisements should be monitored for recency, accuracy, and compliance. Financial institutions should also refer to regulations if the institution's deposit rates appear on third party web sites or as part of a rate sheet summary. These types of messages are not considered advertisements unless the depository institution, or a deposit broker offering accounts at the institution, pays a fee for or otherwise controls the publication.
Disclosures generally are required to be in writing and in a form that the consumer can keep. Until the regulation has been reviewed and changed, if necessary, to allow electronic delivery of disclosures, an institution that wishes to deliver disclosures electronically to consumers, would supplement electronic disclosures with paper disclosures.
PRIVACY STATEMENT - The state of Missouri has filed a lawsuit against Internet merchant More.com, accusing the site of giving personal information about consumers to third parties after promising it would not do so.
IN CLOSING - During the middle of this week, I will be in Washington, DC giving a presentation for the FFIEC to examiners about Internet compliance and Internet security.