The program your regulator expects, built and kept current.
Risk assessments, the board ISP report, vendor risk, continuity, policy, and exam support, run on a cadence by a team that sits in examinations every month. You stay ready, not scrambling.
A security and risk program, run as one accountable function. Not a binder. Not a project.
A named advisor leads the relationship and sits with your board. Behind that advisor is a team that builds and maintains the written program and produces the evidence, on a schedule, so every committee meeting and every exam finds you prepared.
The leadership relationship lives in Strategic Leadership. Continuous monitoring and accountable escalation run through Security Operations. This is the program that ties them together and answers to the regulator.
For the specific questions this program has to answer, see our Examiner Question Bank.
Operations can be outsourced. Accountability is governed.
A named advisor, accountable to the board through a line independent of IT, backed by a team that keeps the written program current. We run the function. You own it.
Enterprise Risk Assessment
Mapped to NIST CSF 2.0, with ransomware readiness, tracked through remediation.
Board ISP Report
The written program reported to the board against GLBA 501(b), FFIEC, and OCC Part 30 Appendix B.
Vendor & TPRM Program
Risk tiering, due diligence, and annual reviews of critical vendors, on a maintained master list.
Continuity & DR
Business continuity, disaster recovery, and incident response plans, tabletop tested and documented.
Audit & Exam Support
We prepare you, sit in the process, and track findings to closure.
Policy & Board Reporting
Policies maintained and reviewed on a committee cadence, so governance is never stale.
The program also covers security awareness and phishing, incident response planning, and AI governance through our AI risk assessment framework.
Independent advice, by design.
In standalone Advisory and virtual CISO engagements, recommendations begin with the institution's risk, regulatory obligations, and operating reality.
Independent of vendors
We stay current on the ecosystem: core, digital banking, fintech, fraud, and the AI platforms. We shortlist, run diligence, and sit in the negotiations with you, then document the selection for the board and the examiner. The recommendation reflects fit, risk, and examiner defensibility, not a vendor quota.
Independent of our own delivery
Advisory stands on its own. You do not have to be a managed IT client, and most advisory clients never are. Where a client buys both, the team that operates the environment and the team that governs it sit on opposite sides of a documented boundary, with separated access. The people grading the work are not the people who did it.
We know what examiners want now, not last year.
We sit in examinations across the country every month. Your program gets the benefit of what examiners are focused on now.
Client banks nationwide, from the low hundreds of millions to over $6 billion in assets.
Experience across all three federal banking regulators.
In audit and examination cycles, every month of the year.
The framework changes. The discipline does not.
Everything above is written in a bank's vocabulary, because the community bank is the hardest version of this problem. The discipline underneath does not change when the examiner does. A program built for FFIEC examination is a strong foundation for a Reg S-P review, a HIPAA audit, or a customer security assessment.
Community banks
FFIEC, GLBA, and OCC Part 30 Appendix B.
Credit unions
NCUA and GLBA.
Wealth & asset management
SEC Regulation S-P and FINRA.
Insurance & benefits
NAIC model rules, state DOI, and HIPAA.
Healthcare systems
HIPAA, HITECH, HHS OCR, and business associate oversight.
Law & professional services
ABA Model Rules, SOC 2, and client due diligence.
Standing up a de novo bank.
The regulatory bar is set the day you charter, not the day you grow into it. We build the security program, governance, and vendor decisions a new bank needs before it opens, then carry them through the de novo period and into steady state.
How we serve de novo banksTell us who you answer to, and where you feel exposed.
We will tell you what readiness should look like, and what the next examination will ask of you.