Banks & Financial Services
FFIEC examiners are asking deeper questions about third-party risk, board oversight, tested resilience, and AI governance — even at institutions that haven't deployed customer-facing AI — while NYDFS Part 500 amendments raise the bar on CISO accountability. We help banks, credit unions, RIAs, broker-dealers, and insurers prepare for examination with materials risk committees can act on.
Overview
FFIEC, NYDFS, and the AI-governance questions your examiners are now asking.
The Pressure
Examiners and regulators are raising the bar faster than most institutions can document.
- FFIEC examiners probe deeper every cycle on third-party risk (under the Interagency Guidance on Third-Party Relationships), board cyber oversight, tested operational resilience, and AI governance — even where no customer-facing AI exists.
- NYDFS 23 NYCRR Part 500 amendments now require independent audit, expanded MFA, and direct board reporting, raising the bar on CISO accountability.
- SEC Cybersecurity Disclosure rules require Form 8-K reporting of material incidents within four business days, and the CFPB's Section 1033 final rule reshapes open-banking data-sharing obligations.
- Wire-fraud and BEC losses keep climbing — IC3 reports record annual totals — while BSA/AML and OFAC enforcement sits at multi-year highs.
- FedNow and real-time rails are creating instant-settlement fraud vectors most institutions have not pressure-tested.
The Gap
The programs on paper cannot answer the questions examiners actually ask.
- TPRM programs produce paperwork but cannot say which vendors are critical, what data they hold, what the contract requires when something fails, or how the institution operates if a vendor disappears tomorrow.
- Risk committees receive 47-page decks they cannot act on instead of board-ready materials tied to decisions.
- CISO board reporting often does not meet what NYDFS Part 500 now requires in form or cadence.
- SEC disclosure and Part 500 are treated as compliance projects rather than operational discipline, so Form 8-K materiality assessment and board cyber-competency demonstration happen reactively.
- AI governance is deferred because no customer-facing AI is live yet — but examiners ask about the program regardless.
How We Help
We run examination-readiness ahead of the exam — not during it.
- Prepare banks, credit unions, RIAs, broker-dealers, and insurers for FFIEC examinations with risk-committee materials leadership can act on.
- Scale a Third-Party Risk Management practice to the actual 500+ vendor inventory with risk-based, criticality-tiered diligence — not a sample of the highest-spend vendors.
- Map GRC programs to FFIEC, NYDFS Part 500, SEC, GLBA Safeguards, and SOX, with CISO reporting cadences that meet Part 500 in form.
- Stand up Applied AI governance that gets in front of the questions examiners are now asking, and pre-position a Breach Retainer with SEC 8-K-aware disclosure support.
- Run SOC, Identity Operations, and Backup & DR mapped directly to the controls examiners scrutinize, led by practitioners who have sat on the bank side.
Walk into the exam with evidence in hand, a clean Part 500 certification, and an AI-governance program already on the record.
Capabilities
What we deliver
FFIEC Examination Readiness
Pre-exam assessments aligned to FFIEC IT Handbook expectations. Gap remediation, evidence preparation, examiner-ready documentation.
GLBA Safeguards Program
Comprehensive information security program design, risk assessments, vendor management, incident response.
NYDFS Part 500 Compliance
CISO designation, written cybersecurity program, third-party diligence, certification of compliance.
SOC 2 & PCI-DSS
For service organizations and card-data environments. Scope reduction, control design, assessor coordination.
Bank Partnership Diligence (FinTech)
Information security questionnaires, evidence packages, and direct engagement with sponsor bank IS teams.
Incident Response (Wire Fraud, BEC)
IR with awareness of fund flows, recovery, regulator notification, and SAR filing requirements.
Pass examinations. Protect customers. Stay innovative.
Let's talk about your exam cycle, compliance roadmap, or modernization needs.