Will Tightening Bank Budgets Impact Security?
The clear message
from banking regulators in their Senate testimony is: Banks are hurting.
The follow-up
question is: Exactly how badly are they hurting, and how will their pain
trickle down to impact information security programs and priorities?
By the FDIC's
estimate, 90 of its institutions are currently on the so-called "Problem Bank
List," up from 77 at the end of last year. These are institutions that
theoretically could fail, but which more likely will be bailed out to weather
the economic storm.
But just because
the institutions survive doesn't mean they'll thrive anytime soon, and that
reality impacts security programs in several ways:
Resources will
remain tight - indicators are that no one is likely to get any additional
headcount or discretionary spending budgets, and there is going to be extra
scrutiny on dollars spent and projects pursued. This condition suggests a couple
of points to consider:
Security leaders are going to have to make a stronger business case
in favor of their key projects. Security for security's sake won't cut it; the
projects that get funded will be the ones that are defined in the greater
context of the institution's business.
Security leaders also may have to think differently about how they
manage risk. What are the strongest, most immediate threats to your institution
and customer trust (identity theft, phishing) vs. those that might feel a little
more distant (i.e. pandemic). Not quite life/death, but security leaders are
going to be forced to make some tough decisions between the risks they mitigate
and those they put on hold.
Outsourcing will
flourish -
in tough times; businesses focus more on their core competencies, and outsource
non-essential tasks and services. This means more reliance on third-party
service providers – such as Managed Security and the growing managed IT services
industry as a whole. Specifically,
Managed Security tops the outsourcing list of priorities in an effort to help
ensure organizations are not subjected to a breach at this particularly
sensitive time.
The Big Will Get
Bigger -
in terms of mergers & acquisitions, this is a great time to be an acquiring
bank. There are plenty of struggling institutions ripe for the picking. But
whether an acquirer or an acquiree, one must be mindful of the role information
security and regulatory compliance must play in M&A activity. Customer trust is
the critical success factor for any banking institution, and it's at risk today
from the security threats that plague banks. Security can't just be part of the
discussion in an M&A; it has to start the conversation.
The benefits of a comprehensive security
audit are very real for both parties.
Compliance Feels
no Downturn - no matter how many institutions are on the "Problem Bank List,"
the Identity Theft Red Flags Rule compliance deadline is still Nov. 1. This is
the ultimate reality facing banking/security leaders: No matter how harsh the
lending crisis or how rocky the economy, identity theft, business continuity and
vendor management are still regulatory compliance mandates that won't go away,
or for which institutions will be given an extension or a break.
And, really, isn't
that the bottom line? It doesn't matter what the regulators say the "State of
the Banking Industry" is, or whether your institutions are in or out of the
proverbial woods. Compliance is the mandatory destination-- it's up to you to
figure out how best to get there.
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