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Operational Risks: Information Security Governance: Ohio, Indiana and Michigan Banks and Credit Unions


Many leading banks and credit unions headquartered in Ohio, Indiana and Michigan face operational risks on information security governance and related consumer protection laws. Corporate identity theft is rampant and a root source of federal crimes against consumers per Presidentís Identity Theft Task Force. Research, using the Information Security Governance Framework on public information, shows firms are failing to fully apply federal regulations on identity theft thus enabling unfair and deceptive acts. Fraudulent domain names used within phishing, email spam and fake web sites are unfair and deceptive practices that attack trade secrets or sensitive customer information, inside and outside of bank IT networks, resulting in operational losses, operational risks and reputational harm for corporations and consumers.

Boards of Directors of financial firms have a fiduciary and regulatory obligation to prevent corporate identity theft. 7 key questions and answers for Audit Committees are included in the Information Security Governance Framework, a holistic, enterprise risk management model. It measures governance, compliance, and operational (legal) risks on identity theft and consumer protection per federal and state regulations and federal banking metrics, i.e., CAMELS and Basel. The model:
∑ synchronizes relevant regulations for the banking industry that include GLBA, FDICIA Section 112, FTC ACT, Lanham Act, Sarbanes-Oxley, Californiaís AB 1950 and FINCENís Identity Theft Suspicious Activity Report requirements with the 3 security layers per GLBA 501(b), 521 and 523, i.e., IT or Information Technology Governance, Network Vulnerability and IP or Intellectual Property Governance.
∑ automates an independent risk management function with external peer review metrics from public information.
∑ generates a positive ROI by minimizing corporate identity theft attacks on consumers and IT networks, operational risks and losses, and capital reductions under Basel.
∑ includes 7 key questions and answers for Boards of Directors on identity theft and information security governance.

River Valley Credit Union, Miamisburg, Ohio, is a role model with an ďAĒ Online Brand Rating, which includes membership in Protecting Consumers Online.

Audit Committees seeking answers to these questions are encouraged to contact the IP Governance Task Force. The Task Force, which provides the Information Security Governance Framework, was formed in 2006 as a multi-disciplinary team of IP professionals. Members include industry thought-leaders from auditing, legal, and technology companies.


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