Financial Services
Your examiner has a checklist. So do we.
Financial institutions are the one sector where cybersecurity is not a judgment call. Somebody with authority will arrive, ask specific questions, and expect documented answers, and the consequences of not having them are regulatory rather than hypothetical.
We support an NCUA-regulated credit union through exactly this. That work is less about installing products and more about producing what the regulator requires: pulling reports for audits, writing and maintaining the internal policies NCUA expects to see, and adjusting technical configurations to meet specific regulatory requirements as they change.
That is the actual job in this sector. Security you cannot evidence does not count.
What makes this different
The pressures specific to financial services.
Examinations are evidence-based
An examiner does not ask whether you have a control. They ask you to demonstrate it, show the policy behind it, and show it has been reviewed. Undocumented security is treated as absent.
Written policies are mandatory, not optional
Information security programs, incident response plans, vendor management, access review procedures. These have to exist, be current, be approved, and be followed, and someone has to maintain them as requirements change.
Vendor risk is your risk
Regulators expect you to assess and monitor the third parties handling member data. Their failure becomes your finding.
Member trust is the whole product
People choose a local institution because they trust it. A breach damages the specific thing that makes you competitive against a national bank with a bigger technology budget.
Small institutions carry the same obligations
A twelve-person credit union faces broadly the same regulatory expectations as a much larger one, without the compliance department. That gap is where we spend most of our time.
What you are measured against
The obligations that actually apply.
- NCUA examination requirements
- Credit unions are examined against information security expectations covering risk assessment, controls, incident response, and board oversight. We produce the reports and evidence requested during examinations, and maintain the internal policies required between them.
- FTC Safeguards Rule
- Applies to a wider set of financial institutions than most realize, including many that do not think of themselves as such. Requires a written information security program, a designated qualified individual, risk assessment, and specific technical controls including encryption and multi-factor authentication.
- GLBA
- The underlying obligation to protect nonpublic personal information, with the Safeguards Rule as its practical expression.
- FFIEC guidance
- The examination handbooks examiners work from. Useful because they say, in detail, what "adequate" is expected to look like.
A client
An NCUA-regulated credit union, twelve people
A small team carrying full regulatory weight. Our work there goes well beyond deploying technology: we pull the reports needed during audits, maintain the internal policies NCUA requires them to hold, and update technical configurations to meet specific regulatory requirements. Their monthly spend rose after the assessment, because examiner-facing gaps had to be closed rather than deferred.
Details anonymized. Figures are real.
- People on staff
- 12
- Examined and supported
- NCUA
Questions we get
From financial services, specifically.
Have you been through an examination with a client?
Yes. We support an NCUA-regulated credit union through audits, producing the reports requested, maintaining the internal policies the regulator expects them to hold, and making technical configuration changes to satisfy specific requirements. We would rather tell you plainly that this is one institution than imply a larger practice than we have.
Do you write the policies, or just the technology?
Both, and in this sector the policies are frequently the harder half. A control that works but has no written policy behind it, no approval, and no review record will still be a finding. We produce and maintain those documents as part of the engagement.
Does the FTC Safeguards Rule apply to us?
It applies to more organizations than most people expect, including many that do not consider themselves financial institutions, such as some lenders, advisors, and firms handling consumer financial data. If you are unsure, that uncertainty is itself worth resolving, and it is a reasonable thing to bring to the first call.
Can you work alongside our existing compliance consultant?
Yes, and it usually works well. They own the regulatory interpretation; we own producing the evidence and making the technical reality match what the policy claims. The gap between those two is where findings come from.
Written for financial services
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Based in Prescott, we work with credit unions and financial firms on-site in Prescott, Prescott Valley, Chino Valley, and Dewey-Humboldt, and remotely across the rest of Arizona.
We also work with
The next step
Find out where your financial service actually stands.
Three minutes, nine areas, no email address. Or book fifteen minutes and we will tell you honestly whether an assessment makes sense for an organization your size.
No pitch on the first call. If we are not a fit, we will say so and point you somewhere better.