Recently, the Massachusetts Division of Banks released examination procedures that incorporate cybersecurity as a module in all of its examinations of banks and non-bank licensees. The procedures contain two separate workbooks. The first, NDIS IT/Information Security Examination Work-program, contains questions related to a Licensee’s (i) risk assessment and management oversight; (ii) written information security program; (iii) data security operations; (iv) business continuity and disaster recovery; (v) cybersecurity; and (vi) IT audit. Section VII of the workbook provides space for an examination summary, and Section VIII of the first workbook contains various links to examination resources, including, but not limited to, the FFIEC Interagency Guidelines Establishing Information Security Standards, and a copy of 201 CMR 17.00 – Standards for the Protection of Personal Information of Residents of the Commonwealth. The second, Non-Depository Institution Supervision Information Technology Officer’s Questionnaire, “contains questions covering significant areas of the Licensee’s [IT] function.”
Last year, the Division sent a communique to CEOs of regulated institutions encouraging them to do a cybersecurity assessment using the FFIEC tool and noted that it would be looking at those assessments in future examinations.