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FDIC Federal Register Citations

[Federal Register: January 20, 1999 (Volume 64, Number 12)]
[Notices]               
[Page 3109-3116]
From the Federal Register Online via GPO Access [wais.access.gpo.gov]
[DOCID:fr20ja99-74]
[[Page 3109]]
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FEDERAL FINANCIAL INSTITUTIONS EXAMINATION COUNCIL
 
Uniform Rating System for Information Technology
AGENCY: Federal Financial Institutions Examination Council.
ACTION: Notice.
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SUMMARY: The Federal Financial Institutions Examination Council (FFIEC) 
revised the Uniform Interagency Rating System for Data Processing 
Operations, commonly referred to as the Information Systems (IS) rating 
system. The revision changed the name of the rating system to the 
Uniform Rating System for Information Technology (URSIT) and reflects 
changes that have occurred in the data processing services industry and 
in supervisory policies and procedures since the rating system was 
first adopted in 1978. The revised numerical ratings conform to the 
language and tone of the Uniform Financial Institution Rating System 
(UFIRS) rating definitions, commonly referred to as the CAMELS rating 
system; reformatted and clarified the component rating descriptions; 
emphasized the quality of risk management processes in each of the 
rating components; added two new component categories, ``Development 
and Acquisition'', and ``Support and Delivery'' as replacements for 
``Systems Development and Programming'', and ``Operations''; and 
explicitly identified the risk types that are considered in assigning 
component ratings.
    The term ``financial institution'' refers to those FDIC insured 
depository institutions whose primary Federal supervisory agency is 
represented on the FFIEC, Bank Holding Companies, Branches and Agencies 
of Foreign Banking Organizations, and Thrifts. The term ``service 
provider'' refers to organizations that provide data processing 
services to financial institutions. Uninsured trust companies that are 
chartered by the Office of the Comptroller of the Currency (OCC), 
members of the Federal Reserve System, or subsidiaries of registered 
bank holding companies or insured depository institutions are also 
covered by this action.
FOR FURTHER INFORMATION CONTACT:
    FRB: Charles Blaine Jones, Supervisory EDP Analyst, Specialized 
Activities, (202) 452-3759, Division of Banking Supervision and 
Regulation, Board of Governors of the Federal Reserve System, Mail Stop 
175, 20th and C Streets, NW, Washington, D.C. 20551.
    FDIC: Stephen A. White, Review Examiner (Information Systems), 
(202) 898-6923, Division of Supervision, Federal Deposit Insurance 
Corporation, Room F-6010, 550 17th Street, NW, Washington, D.C. 20429.
    OCC: Robert J. Hemming, National Bank Examiner, (202) 874-4929, 
Bank Technology Unit, Office of the Comptroller of the Currency, Mail 
Stop 7-8, 250 E Street, SW, Washington, D.C. 20219.
    OTS: Jennifer Dickerson, Program Manager, Information System 
Examinations, Compliance Policy, (202) 906-5631, Office of Thrift 
Supervision, 1700 G Street, NW, Washington, D.C. 20552.
SUPPLEMENTARY INFORMATION:
Background Information
    On June 9, 1998, the FFIEC published a notice in the Federal 
Register (June Notice), 63 FR 31468-31475, requesting comment on 
proposed revisions to the Uniform Interagency Rating System for Data 
Processing Operations. This rating system is an internal supervisory 
examination rating system used by federal and state regulators to 
assess uniformly financial institution and service provider risks 
introduced by information technology and for identifying those 
institutions and service providers requiring special supervisory 
attention. The current rating system was adopted in 1978 by the OCC, 
OTS, FDIC and FRB, and is commonly referred to as the IS rating system. 
Under the IS rating system, each financial institution or service 
provider is assigned a composite rating based on an evaluation and 
rating of four essential components of an institution's information 
technology activities. These components address the following: the 
adequacy of the information technology audit function; the capability 
of information technology management; the adequacy of systems 
development and programming; and the quality, reliability, availability 
and integrity of information technology operations. The composite and 
component ratings are assigned on a ``1'' to ``5'' numerical scale. A 
rating of ``1'' indicates the strongest performance and management 
practices and the least degree of supervisory concern, while a rating 
of ``5'' indicates the weakest performance and management practices 
and, therefore, the highest degree of supervisory concern.
    The IS rating system has proven to be an effective means for the 
federal and state supervisory agencies to assist examiners in 
determining the condition of an institution's or service provider's 
information technology function. A number of changes, however, have 
occurred in information technology and in supervisory policies and 
procedures since the rating system was first adopted. As a result the 
FFIEC is renaming the rating system to the Uniform Rating System for 
Information Technology (URSIT) and making certain enhancements to the 
rating system, while retaining its basic framework. The URSIT 
enhancements:
    {time}  Realign the URSIT rating definitions to bring them in line 
with UFIRS.
    {time}  Replace the current ``Systems Development and Programming'' 
and ``Operations'' components with two new component categories, 
``Development and Acquisition'' and ``Support and Delivery''.
    {time}  Reinforce the importance of risk management processes with 
language in each of the rating components emphasizing the consideration 
of processes to identify, measure, monitor, and control risks.
Comments Received and Changes Made
    The FFIEC received eight comments regarding the proposed revisions 
to the URSIT. Three of the comments were from banks and credit unions, 
two from third party service providers, two from financial institution 
trade associations, and one from a technology vendor.
    Examiners field-tested the revised rating system during bank and 
thrift information system examinations conducted between June and 
August 1998. The examiners provided comments regarding the revised 
rating system. Examiner responses were generally favorable, and no 
significant problems or unanticipated rating differences were 
encountered between the former and updated rating system.
    The FFIEC carefully considered each comment and examiner response 
and made certain changes. The following discussion describes the 
comments received (both through public comment and agency field-
testing) and changes made to the URSIT in response to those comments. 
The updated URSIT is included at the end of this Notice.
June Notice Specific Questions
    In addition to requesting general comments regarding the proposed 
system, the FFIEC invited comments on six specific questions:
    1. Does the proposal capture the essential risk areas of 
information technology?
    The majority of the responses to this question were positive, and 
no changes were made. One commenter expressed concerns that the 
significance of contingency planning in maintaining
[[Page 3110]]
mission-critical applications in the event of a computer system failure 
was not adequately addressed. This concern is addressed later in this 
Notice under Contingency Planning.
    2. Does the proposal adequately address distributed processing 
environments, as well as centralized processing environments?
    The majority of the responses to this question were positive. Two 
commenters expressed concerns that the proposal did not adequately 
address distributed processing environments. One commenter recommended 
that specific language be used to emphasize network security issues, 
electronic commerce, and Internet controls. The FFIEC has added 
language to the Support and Delivery component to explicitly include 
electronic commerce and the Internet. One commenter expressed concerns 
that the proposal does not address the complexities and risks of 
contingency planning and data recovery in a distributed processing 
environment. This concern is addressed later in this Notice under Data 
Processing Service Providers and Contingency Planning.
    3. Does the proposal adequately address risks to financial 
institutions that process their data in-house as well as to data 
processing service providers?
    The majority of responses to this question were positive. Three 
commenters noted concerns regarding the proposal's adequacy to address 
risks to data processing service providers. This concern is addressed 
later in this Notice under Data Processing Service Providers.
    4. Are the definitions for the individual components and the 
composite numerical ratings in the proposal consistent with the 
language and tone of the UFIRS definitions?
    The majority of responses to this question were positive. Two 
commenters recommended revisions in the language of the proposal to 
make it more consistent with UFIRS. The FFIEC made additional changes 
in the language of the URSIT to make it more consistent with UFIRS.
    5. Are there any components which should be added to or deleted 
from the proposal?
    The majority of the responses to this question were negative. One 
commenter recommended that a fifth component entitled ``Contingency 
Planning'' be added to the URSIT. This recommendation is addressed 
later in this Notice under Contingency Planning.
    6. Given the trend toward the integration of safety and soundness 
and information technology examination functions by the federal 
supervisory agencies, does a separate rating system for information 
technology continue to be useful?
    The majority of the responses to this question were positive, and 
no changes were made. One commenter suggested that the integration of 
the examination functions deserve more study. This commenter expressed 
a concern that the convergence of information technology applications 
to the operation of the payments system is likely to result in 
considerable duplication in the examination process and an inconsistent 
evaluation of risk management procedures for information technology 
activities and payments system risk. The FFIEC is working toward the 
integration of the safety and soundness and information technology 
examination functions. This concern is addressed later in this notice 
under Risk Management.
Data Processing Service Providers
    Two commenters expressed concerns that the URSIT provides little 
guidance regarding the differentiation of data processing service 
providers whose operations vary by size and complexity. The FFIEC 
designed the rating system so that examiners could adapt its concepts 
to entities of various size and complexity. Examination strategies and 
objectives are written based on the guidelines in the FFIEC Information 
Systems Examination Handbook 1 (IS Handbook). Specifically 
for data processing service providers this guidance is contained in 
Chapter 22 of the IS Handbook and generally for all entities in 
Chapters 2 through 5. The FFIEC oversees the application of the URSIT 
through its Information Systems Subcommittee. Future editions of the 
FFIEC IS Handbook will be reviewed and edited to ensure it continues to 
provide appropriate guidance for the application of the URSIT to all 
data processing service providers.
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    \1\ Federal Financial Institutions Examination Council, 
Information Systems Examination Handbook, 1996.
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    One commenter expressed a concern that the URSIT does not 
adequately address what banks, who use data processing service 
providers, should do in situations where their control is limited. 
Guidance for banks who receive data processing services is available 
from Chapter 22 of the FFIEC IS Handbook. This chapter specifically 
addresses control and administration issues in contracting with and 
monitoring service providers. The FFIEC designed the URSIT so that 
examiners could apply the concepts of the rating system to institutions 
who perform their data processing in-house as well as to those 
institutions who outsource this function to a third-party. The 
flexibility of the URSIT allows an examiner to include, within the 
scope of examination, the appropriate requirements and exclude those 
requirements that do not apply.
Risk Management
    The revised rating system reflects an increased emphasis on risk 
management processes. One commenter expressed concern about whether the 
increased emphasis on risk management in the URSIT will be implemented 
and applied in a manner that is consistent with risk management 
principles articulated in other bank supervision initiatives, 
particularly those dealing with payments system risk. The FFIEC is 
working toward the integration of the safety and soundness and 
information technology examination functions. The future implementation 
of an integrated examination process by the FFIEC will need to address 
the consistent application of risk management principles and oversight 
of information technology activities and other operational areas. 
Accordingly, the FFIEC will review the URSIT periodically to ensure its 
compatibility with the evolving examination process. In the interim, 
the assessment of information technology risk management is guided by 
Chapter 2 of the FFIEC IS Handbook and other policy statements deemed 
appropriate.
Contingency Planning
    One commenter suggested that the URSIT should formally address 
contingency planning guidelines under a separate rating to assess an 
institution's ability to quickly recover from a major disruption 
without risking a loss of its data. The commenter suggested the URSIT 
should include ratings that reflect a more comprehensive assessment of 
an institution's contingency plan and that they should define the time 
needed for an institution to resume core applications.
    The FFIEC agrees that contingency planning and business resumption 
is important to the viability of any financial institution. To 
supervise and assess these activities, the FFIEC's revised interagency 
policy on Corporate Business Resumption and Contingency Planning (SP-5) 
provides general policies for financial institutions. This policy 
establishes goals and accountability for contingency planning and 
defines a financial institution's responsibilities regarding 
contingency
[[Page 3111]]
planning if they have outsourced information processing. The FFIEC IS 
Handbook, which provides general control and verification procedures 
for examiners, supplements this policy. The IS Handbook also provides 
reference information that supports the contingency planning 
procedures. The IS Handbook guidance is considered sufficient to assess 
the adequacy of the financial institution's contingency planning 
efforts.
    The rating system includes contingency planning as part of the 
assessment of the support and delivery component. The FFIEC considered 
stratification of the rating system components based on functional 
controls, e.g., contingency planning or security, and chose to use the 
model created by the Information Systems Audit and Control Foundation, 
COBIT.2 The FFIEC concluded that further breakdown was not 
necessary or beneficial to the examiners or financial institutions.
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    \2\ Information Systems Audit and Control Foundation, COBIT--
Governance, Control and Audit for Information and Related 
Technology, Second Edition.
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Implementation Date
    The FFIEC recommends that the Federal supervisory agencies 
implement the updated URSIT no later than April 1, 1999.
Uniform Rating System for Information Technology
Introduction
    The quality, reliability, and integrity of a financial institution 
or service provider's information technology (IT) affects all aspects 
of its performance. An assessment of the technology risk management 
framework is necessary whether or not the institution or a third-party 
service provider manages these operations. The Uniform Rating System 
for Information Technology (URSIT) is an internal rating system used by 
federal and state regulators to uniformly assess financial institution 
and service provider risks introduced by IT. It also allows the 
regulators to identify those insured institutions and service providers 
whose information technology risk exposure or performance requires 
special supervisory attention. The rating system includes component and 
composite rating descriptions and the explicit identification of risks 
and assessment factors that examiners consider in assigning component 
ratings. Additionally, information technology can affect the risks 
associated with financial institutions. The effect on credit, 
operational, market, reputation, strategic, liquidity, interest rate, 
and compliance risks should be considered for each IT rating component.
    The primary purpose of the rating system is to identify those 
entities whose condition or performance of information technology 
functions requires special supervisory attention. This rating system 
assists examiners in making an assessment of risk and compiling 
examination findings. However, the rating system does not drive the 
scope of an examination. Examiners should use the rating system to help 
evaluate the entity's overall risk exposure and risk management 
performance, and determine the degree of supervisory attention believed 
necessary to ensure that weaknesses are addressed and that risk is 
properly managed.
Overview
    The URSIT is based on a risk evaluation of four critical 
components: Audit, Management, Development and Acquisition, and Support 
and Delivery (AMDS). These components are used to assess the overall 
performance of IT within an organization. Examiners evaluate the 
functions identified within each component to assess the institution's 
ability to identify, measure, monitor and control information 
technology risks. Each organization examined for IT is assigned a 
summary or composite rating based on the overall results of the 
evaluation. The IT composite rating and each component rating are based 
on a scale of ``1'' through ``5'' in ascending order of supervisory 
concern; ``1'' representing the highest rating and least degree of 
concern, and ``5'' representing the lowest rating and highest degree of 
concern.
    The first step in developing an IT composite rating for an 
organization is the assignment of a performance rating to the 
individual AMDS components. The evaluation of each of these components, 
their interrelationships, and relative importance is the basis for the 
composite rating. The composite rating is derived by making a 
qualitative summarization of all of the AMDS components. A direct 
relationship exists between the composite rating and the individual 
AMDS component performance ratings. However, the composite rating is 
not an arithmetic average of the individual components. An arithmetic 
approach does not reflect the actual condition of IT when using a risk-
focused approach. A poor rating in one component may heavily influence 
the overall composite rating for an institution. For example, if the 
audit function is viewed as inadequate, the overall integrity of the IT 
systems is not readily verifiable. Thus, a composite rating of less 
than satisfactory (``3''-``5'') would normally be appropriate.
    A principal purpose of the composite rating is to identify those 
financial institutions and service providers that pose an inordinate 
amount of information technology risk and merit special supervisory 
attention. Thus, individual risk exposures that more explicitly affect 
the viability of the organization and/or its customers should be given 
more weight in the composite rating.
    The FFIEC recognizes that management practices, particularly as 
they relate to risk management, vary considerably among financial 
institutions and service bureaus depending on their size and 
sophistication, the nature and complexity of their business activities 
and their risk profile. Accordingly, the FFIEC also recognizes that for 
less complex information systems environments, detailed or highly 
formalized systems and controls are not required to receive the higher 
composite and component ratings.
    The following two sections contain the URSIT composite rating 
definitions, the assessment factors, and definitions for the four 
component ratings. These assessment factors and definitions outline 
various IT functions and controls that may be evaluated as part of the 
examination.
Composite Ratings 3
Composite 1
    Financial institutions and service providers rated composite ``1'' 
exhibit strong performance in every respect and generally have 
components rated 1 or 2. Weaknesses in IT are minor in nature and are 
easily corrected during the normal course of business. Risk management 
processes provide a comprehensive program to identify and monitor risk 
relative to the size, complexity and risk profile of the entity. 
Strategic plans are well defined and fully integrated throughout the 
organization. This allows management to quickly adapt to changing 
market, business and technology needs of the entity. Management 
identifies weaknesses promptly and takes appropriate corrective action 
to resolve audit and regulatory concerns. The
[[Page 3112]]
financial condition of the service provider is strong and overall 
performance shows no cause for supervisory concern.
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    \3\ The descriptive examples in the numeric composite rating 
definitions are intended to provide guidance to examiners as they 
evaluate the overall condition of Information Technology. Examiners 
must use professional judgement when making this assessment and 
assigning the numeric rating.
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Composite 2
    Financial institutions and service providers rated composite ``2'' 
exhibit safe and sound performance but may demonstrate modest 
weaknesses in operating performance, monitoring, management processes 
or system development. Generally, senior management corrects weaknesses 
in the normal course of business. Risk management processes adequately 
identify and monitor risk relative to the size, complexity and risk 
profile of the entity. Strategic plans are defined but may require 
clarification, better coordination or improved communication throughout 
the organization. As a result, management anticipates, but responds 
less quickly to changes in market, business, and technological needs of 
the entity. Management normally identifies weaknesses and takes 
appropriate corrective action. However, greater reliance is placed on 
audit and regulatory intervention to identify and resolve concerns. The 
financial condition of the service provider is acceptable and while 
internal control weaknesses may exist, there are no significant 
supervisory concerns. As a result, supervisory action is informal and 
limited.
Composite 3
    Financial institutions and service providers rated composite ``3'' 
exhibit some degree of supervisory concern due to a combination of 
weaknesses that may range from moderate to severe. If weaknesses 
persist, further deterioration in the condition and performance of the 
institution or service provider is likely. Risk management processes 
may not effectively identify risks and may not be appropriate for the 
size, complexity, or risk profile of the entity. Strategic plans are 
vaguely defined and may not provide adequate direction for IT 
initiatives. As a result, management often has difficulty responding to 
changes in business, market, and technological needs of the entity. 
Self-assessment practices are weak and are generally reactive to audit 
and regulatory exceptions. Repeat concerns may exist, indicating that 
management may lack the ability or willingness to resolve concerns. The 
financial condition of the service provider may be weak and/or negative 
trends may be evident. While financial or operational failure is 
unlikely, increased supervision is necessary. Formal or informal 
supervisory action may be necessary to secure corrective action.
Composite 4
    Financial institutions and service providers rated composite ``4'' 
operate in an unsafe and unsound environment that may impair the future 
viability of the entity. Operating weaknesses are indicative of serious 
managerial deficiencies. Risk management processes inadequately 
identify and monitor risk, and practices are not appropriate given the 
size, complexity, and risk profile of the entity. Strategic plans are 
poorly defined and not coordinated or communicated throughout the 
organization. As a result, management and the board are not committed 
to, or may be incapable of ensuring that technological needs are met. 
Management does not perform self-assessments and demonstrates an 
inability or unwillingness to correct audit and regulatory concerns. 
The financial condition of the service provider is severely impaired 
and/or deteriorating. Failure of the financial institution or service 
provider may be likely unless IT problems are remedied. Close 
supervisory attention is necessary and, in most cases, formal 
enforcement action is warranted.
Composite 5
    Financial institutions and service providers rated composite ``5'' 
exhibit critically deficient operating performance and are in need of 
immediate remedial action. Operational problems and serious weaknesses 
may exist throughout the organization. Risk management processes are 
severely deficient and provide management little or no perception of 
risk relative to the size, complexity, and risk profile of the entity. 
Strategic plans do not exist or are ineffective, and management and the 
board provide little or no direction for IT initiatives. As a result, 
management is unaware of, or inattentive to technological needs of the 
entity. Management is unwilling or incapable of correcting audit and 
regulatory concerns. The financial condition of the service provider is 
poor and failure is highly probable due to poor operating performance 
or financial instability. Ongoing supervisory attention is necessary.
Component Ratings 4
Audit
    Financial institutions and service providers are expected to 
provide independent assessments of their exposure to risks and the 
quality of internal controls associated with the acquisition, 
implementation and use of information technology.5 Audit 
practices should address the IT risk exposures throughout the 
institution and its service provider(s) in the areas of user and data 
center operations, client/server architecture, local and wide area 
networks, telecommunications, information security, electronic data 
interchange, systems development, and contingency planning. This rating 
should reflect the adequacy of the organization's overall IT audit 
program, including the internal and external auditor's abilities to 
detect and report significant risks to management and the board of 
directors on a timely basis. It should also reflect the internal and 
external auditor's capability to promote a safe, sound, and effective 
operation.
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    \4\ The descriptive examples in the numeric component rating 
definitions are intended to provide guidance to examiners as they 
evaluate the individual components. Examiners must use professional 
judgement when assessing a component area and assigning a numeric 
rating value as it is likely that examiners will encounter 
conditions that correspond to descriptive examples in two or more 
numeric rating value definitions.
    \5\ Financial institutions that outsource their data processing 
operations should obtain copies of internal audit reports, SAS 70 
reviews, and/or regulatory examination reports of their service 
providers.
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    The performance of audit is rated based upon an assessment of 
factors such as:
    {time}  The level of independence maintained by audit and the 
quality of the oversight and support provided by the board of directors 
and management.
    {time}  The adequacy of audit's risk analysis methodology used to 
prioritize the allocation of audit resources and to formulate the audit 
schedule.
    {time}  The scope, frequency, accuracy, and timeliness of internal 
and external audit reports.
    {time}  The extent of audit participation in application 
development, acquisition, and testing, to ensure the effectiveness of 
internal controls and audit trails.
    {time}  The adequacy of the overall audit plan in providing 
appropriate coverage of IT risks.
    {time}  The auditor's adherence to codes of ethics and professional 
audit standards.
    {time}  The qualifications of the auditor, staff succession, and 
continued development through training.
    {time}  The existence of timely and formal follow-up and reporting 
on management's resolution of identified problems or weaknesses.
    {time}  The quality and effectiveness of internal and external 
audit activity as it relates to IT controls.
[[Page 3113]]
 Ratings
    1. A rating of ``1'' indicates strong audit performance. Audit 
independently identifies and reports weaknesses and risks to the board 
of directors or its audit committee in a thorough and timely manner. 
Outstanding audit issues are monitored until resolved. Risk analysis 
ensures that audit plans address all significant IT operations, 
procurement, and development activities with appropriate scope and 
frequency. Audit work is performed in accordance with professional 
auditing standards and report content is timely, constructive, 
accurate, and complete. Because audit is strong, examiners may place 
substantial reliance on audit results.
    2. A rating of ``2'' indicates satisfactory audit performance. 
Audit independently identifies and reports weaknesses and risks to the 
board of directors or audit committee, but reports may be less timely. 
Significant outstanding audit issues are monitored until resolved. Risk 
analysis ensures that audit plans address all significant IT 
operations, procurement, and development activities; however, minor 
concerns may be noted with the scope or frequency. Audit work is 
performed in accordance with professional auditing standards; however, 
minor or infrequent problems may arise with the timeliness, 
completeness and accuracy of reports. Because audit is satisfactory, 
examiners may rely on audit results but because minor concerns exist, 
examiners may need to expand verification procedures in certain 
situations.
    3. A rating of ``3'' indicates less than satisfactory audit 
performance. Audit identifies and reports weaknesses and risks; 
however, independence may be compromised and reports presented to the 
board or audit committee may be less than satisfactory in content and 
timeliness. Outstanding audit issues may not be adequately monitored. 
Risk analysis is less than satisfactory. As a result, the audit plan 
may not provide sufficient audit scope or frequency for IT operations, 
procurement, and development activities. Audit work is generally 
performed in accordance with professional auditing standards; however, 
occasional problems may be noted with the timeliness, completeness and/
or accuracy of reports. Because audit is less than satisfactory, 
examiners must use caution if they rely on the audit results.
    4. A rating of ``4'' indicates deficient audit performance. Audit 
may identify weaknesses and risks but it may not independently report 
to the board or audit committee and report content may be inadequate. 
Outstanding audit issues may not be adequately monitored and resolved. 
Risk analysis is deficient. As a result, the audit plan does not 
provide adequate audit scope or frequency for IT operations, 
procurement, and development activities. Audit work is often 
inconsistent with professional auditing standards and the timeliness, 
accuracy, and completeness of reports is unacceptable. Because audit is 
deficient, examiners cannot rely on audit results.
    5. A rating of ``5'' indicates critically deficient audit 
performance. If an audit function exists, it lacks sufficient 
independence and, as a result, does not identify and report weaknesses 
or risks to the board or audit committee. Outstanding audit issues are 
not tracked and no follow-up is performed to monitor their resolution. 
Risk analysis is critically deficient. As a result, the audit plan is 
ineffective and provides inappropriate audit scope and frequency for IT 
operations, procurement and development activities. Audit work is not 
performed in accordance with professional auditing standards and major 
deficiencies are noted regarding the timeliness, accuracy, and 
completeness of audit reports. Because audit is critically deficient 
examiners cannot rely on audit results.
Management
    This rating reflects the abilities of the board and management as 
they apply to all aspects of IT acquisition, development, and 
operations. Management practices may need to address some or all of the 
following IT-related risks: strategic planning, quality assurance, 
project management, risk assessment, infrastructure and architecture, 
end-user computing, contract administration of third party service 
providers, organization and human resources, regulatory and legal 
compliance. Generally, directors need not be actively involved in day-
to-day operations; however, they must provide clear guidance regarding 
acceptable risk exposure levels and ensure that appropriate policies, 
procedures, and practices have been established. Sound management 
practices are demonstrated through active oversight by the board of 
directors and management, competent personnel, sound IT plans, adequate 
policies and standards, an effective control environment, and risk 
monitoring. This rating should reflect the board's and management's 
ability as it applies to all aspects of IT operations.
    The performance of management and the quality of risk management 
are rated based upon an assessment of factors such as:
    {time}  The level and quality of oversight and support of the IT 
activities by the board of directors and management.
    {time}  The ability of management to plan for and initiate new 
activities or products in response to information needs and to address 
risks that may arise from changing business conditions.
    {time}  The ability of management to provide information reports 
necessary for informed planning and decision making in an effective and 
efficient manner.
    {time}  The adequacy of, and conformance with, internal policies 
and controls addressing the IT operations and risks of significant 
business activities.
    {time}  The effectiveness of risk monitoring systems.
    {time}  The timeliness of corrective action for reported and known 
problems.
    {time}  The level of awareness of and compliance with laws and 
regulations.
    {time}  The level of planning for management succession.
    {time}  The ability of management to monitor the services delivered 
and to measure the organization's progress toward identified goals in 
an effective and efficient manner.
    {time}  The adequacy of contracts and management's ability to 
monitor relationships with third-party servicers.
    {time}  The adequacy of strategic planning and risk management 
practices to identify, measure, monitor, and control risks, including 
management's ability to perform self-assessments.
    {time}  The ability of management to identify, measure, monitor, 
and control risks and to address emerging information technology needs 
and solutions.
    In addition to the above, factors such as the following are 
included in the assessment of management at service providers:
    {time}  The financial condition and ongoing viability of the 
entity.
    {time}  The impact of external and internal trends and other 
factors on the ability of the entity to support continued servicing of 
client financial institutions.
    {time}  The propriety of contractual terms and plans.
Ratings
    1. A rating of ``1'' indicates strong performance by management and 
the board. Effective risk management practices are in place to guide IT 
activities, and risks are consistently and effectively identified, 
measured, controlled, and monitored. Management immediately resolves 
audit and regulatory concerns to ensure sound operations. Written 
technology plans, policies and procedures, and standards
[[Page 3114]]
are thorough and properly reflect the complexity of the IT environment. 
They have been formally adopted, communicated, and enforced throughout 
the organization. IT systems provide accurate, timely reports to 
management. These reports serve as the basis of major decisions and as 
an effective performance-monitoring tool. Outsourcing arrangements are 
based on comprehensive planning; routine management supervision 
sustains an appropriate level of control over vendor contracts, 
performance, and services provided. Management and the board have 
demonstrated the ability to promptly and successfully address existing 
IT problems and potential risks.
    2. A rating of ``2'' indicates satisfactory performance by 
management and the board. Adequate risk management practices are in 
place and guide IT activities. Significant IT risks are identified, 
measured, monitored, and controlled; however, risk management processes 
may be less structured or inconsistently applied and modest weaknesses 
exist. Management routinely resolves audit and regulatory concerns to 
ensure effective and sound operations, however, corrective actions may 
not always be implemented in a timely manner. Technology plans, 
policies and procedures, and standards are adequate and are formally 
adopted. However, minor weaknesses may exist in management's ability to 
communicate and enforce them throughout the organization. IT systems 
provide quality reports to management which serve as a basis for major 
decisions and a tool for performance planning and monitoring. Isolated 
or temporary problems with timeliness, accuracy or consistency of 
reports may exist. Outsourcing arrangements are adequately planned and 
controlled by management, and provide for a general understanding of 
vendor contracts, performance standards and services provided. 
Management and the board have demonstrated the ability to address 
existing IT problems and risks successfully.
    3. A rating of ``3'' indicates less than satisfactory performance 
by management and the board. Risk management practices may be weak and 
offer limited guidance for IT activities. Most IT risks are generally 
identified; however, processes to measure and monitor risk may be 
flawed. As a result, management's ability to control risk is less than 
satisfactory. Regulatory and audit concerns may be addressed, but time 
frames are often excessive and the corrective action taken may be 
inappropriate. Management may be unwilling or incapable of addressing 
deficiencies. Technology plans, policies and procedures, and standards 
exist, but may be incomplete. They may not be formally adopted, 
effectively communicated, or enforced throughout the organization. IT 
systems provide requested reports to management, but periodic problems 
with accuracy, consistency and timeliness lessen the reliability and 
usefulness of reports and may adversely affect decision making and 
performance monitoring. Outsourcing arrangements may be entered into 
without thorough planning. Management may provide only cursory 
supervision that limits their understanding of vendor contracts, 
performance standards, and services provided. Management and the board 
may not be capable of addressing existing IT problems and risks, 
evidenced by untimely corrective actions for outstanding IT problems.
    4. A rating of ``4'' indicates deficient performance by management 
and the board. Risk management practices are inadequate and do not 
provide sufficient guidance for IT activities. Critical IT risk are not 
properly identified, and processes to measure and monitor risks are 
deficient. As a result, management may not be aware of and is unable to 
control risks. Management may be unwilling and/or incapable of 
addressing audit and regulatory deficiencies in an effective and timely 
manner. Technology plans, policies and procedures, and standards are 
inadequate, have not been formally adopted, or effectively communicated 
throughout the organization, and management does not effectively 
enforce them. IT systems do not routinely provide management with 
accurate, consistent, and reliable reports, thus contributing to 
ineffective performance monitoring and/or flawed decision making. 
Outstanding arrangements may be entered into without planning or 
analysis, and management may provide little or no supervision of vendor 
contracts, performance standards, or services provided. Management and 
the board are unable to address existing IT problems and risks, as 
evidenced by ineffective actions and longstanding IT weaknesses. 
Strengthening of management and its processes is necessary. The 
financial condition of the service provider may threaten its viability.
    5. A rating of ``5'' indicates critically deficient performance by 
management and the board. Risk management practices are severely flawed 
and provide inadequate guidance for IT activities. Critical IT risks 
are not identified, and processes to measure and monitor risks do not 
exist, or are not effective. Management's inability to control risk may 
threaten the continued viability of the institution or service 
provider. Management is unable and/or unwilling to correct audit and 
regulatory identified deficiencies and immediate action by the board is 
required to preserve the viability of the institution or service 
provider. If they exist, technology plans, policies and procedures, and 
standards are critically deficient. Because of systemic problems, IT 
systems do not produce management reports which are accurate, timely, 
or relevant. Outsourcing arrangements may have been entered into 
without management planning or analysis, resulting in significant 
losses to the financial institution or ineffective vendor services. The 
financial condition of the service provider presents an imminent threat 
to its viability.
Development and Acquisition
    This rating reflects an organization's ability to identify, 
acquire, install, and maintain appropriate information technology 
solutions. Management practices may need to address all or parts of the 
business process for implementing any kind of change to the hardware or 
software used. These business processes include an institution's or 
service provider's purchase of hardware or software, development and 
programming performed by the institution or service provider, purchase 
of services from independent vendors or affiliated data centers, or a 
combination of these activities. The business process is defined as all 
phases taken to implement a change including researching alternatives 
available, choosing an appropriate option for the organization as a 
whole, and converting to the new system, or integrating the new system 
with existing systems. This rating reflects the adequacy of the 
institution's systems development methodology and related risk 
management practices for acquisition and deployment of information 
technology. This rating also reflects the boards and management's 
ability to enhance and replace information technology prudently in a 
controlled environment,
    The performance of systems development and acquisition and related 
risk management practice is rated based upon an assessment of factors 
such as:
    {time}  The level and quality of oversight and support of systems 
development and acquisition activities by senior management and the 
board of directors.
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    {time}  The adequacy of the organizational and management 
structures to establish accountability and responsibility for IT 
systems and technology initiatives.
    {time}  The volume, nature, and extent of risk exposure to the 
financial institution in the area of systems development and 
acquisition.
    {time}  The adequacy of the institution's Systems Development Life 
Cycle (SDLC) and programming standards.
    {time}  The quality of project management programs and practices 
which are followed by developers, operators, executive management/
owners, independent vendors or affiliated servicers, and end-users.
    {time}  The independence of the quality assurance function and the 
adequacy of controls over program changes.
    {time}  The quality and thoroughness of system documentation.
    {time}  The integrity and security of the network, system, and 
application software.
    {time}  The development of information technology solutions that 
meet the needs of end users.
    {time}  The extent of end user involvement in the system 
development process.
    In addition to the above, factors such as the following are 
included in the assessment of development and acquisition at service 
providers:
    {time}  The quality of software releases and documentation.
    {time}  The adequacy of training provided to clients.
Ratings
    1. A rating of ``1'' indicates strong systems development, 
acquisition, implementation, and change management performance. 
Management and the board routinely demonstrate successfully the ability 
to identify and implement appropriate IT solutions while effectively 
managing risk. Project management techniques and the SDLC are fully 
effective and supported by written policies, procedures and project 
controls that consistently result in timely and efficient project 
completion. An independent quality assurance function provides strong 
controls over testing and program change management. Technology 
solutions consistently meet end user needs. No significant weaknesses 
or problems exist.
    2. A rating of ``2'' indicates satisfactory systems development, 
acquisition, implementation, and change management performance. 
Management and the board frequently demonstrate the ability to identify 
and implement appropriate IT solutions while managing risk. Project 
management and the SDLC are generally effective; however, weaknesses 
may exist that result in minor project delays or cost overruns. An 
independent quality assurance function provides adequate supervision of 
testing and program change management, but minor weaknesses may exist. 
Technology solutions meet end user needs. However, minor enhancements 
may be necessary to meet original user expectations. Weaknesses may 
exist; however, they are not significant and they are easily corrected 
in the normal course of business.
    3. A rating of ``3'' indicates less than satisfactory systems 
development, acquisition, implementation, and change management 
performance. Management and the board may often be unsuccessful in 
identifying and implementing appropriate IT solutions; therefore, 
unwarranted risk exposure may exist. Project management techniques and 
the SDLC are weak and may result in frequent project delays, backlogs 
or significant cost overruns. The quality assurance function may not be 
independent of the programming function which may adversely impact the 
integrity of testing and program change management. Technology 
solutions generally meet end user needs, but often require an 
inordinate level of change after implementation. Because of weaknesses, 
significant problems may arise that could result in disruption to 
operations or significant losses.
    4. A rating of ``4'' indicates deficient systems development, 
acquisition, implementation and change management performance. 
Management and the board may be unable to identify and implement 
appropriate IT solutions and do not effectively mange risk. Project 
management techniques and the SDLC are ineffective and may result in 
severe project delays and cost overruns. The quality assurance function 
is not fully effective and may not provide independent or comprehensive 
review of testing controls or program change management. Technology 
solutions may not meet the critical needs of the organization. Problems 
and significant risks exist that require immediate action by the board 
and management to preserve the soundness of the institution.
    5. A rating of ``5'' indicates critically deficient systems 
development, acquisition, impelementation, and change management 
performance. Management and the board appear to be incapable of 
identifying, and implementing appropriate information technology 
solutions. If they exist, project management techniques and the SDLC 
are critically deficient and provide little or no direction for 
development of systems or technology projects. The quality assurance 
function is severely deficient or not present and unidentified problems 
in testing and program change management have caused significant IT 
risks. Technology solutions do not meet the needs of the organization. 
Serious problems and significant risks exist which raise concern for 
the financial institution's or service providers's ongoing viability.
Support and Delivery
    This rating reflects an organization's ability to provide 
technology services in a secure environment. It reflects not only the 
condition of IT operations but also factors such as reliability, 
security, and integrity, which may affect the quality of the 
information delivery system. The factors include customer support and 
training, and the ability to manage problems and incidents, operations, 
system performance, capacity planning, and facility and data 
management. Risk management practices should promote effective, safe 
and sound IT operations that ensure the continuity of operations and 
the reliability and availability of data. The scope of this component 
rating includes operational risks throughout the organization and 
service providers.
    The rating of IT support and delivery is based on a review and 
assessment of requirements such as:
    {time}  The ability to provide a level of service that meets the 
requirements of the business.
    {time}  The adequacy of security policies, procedures, and 
practices in all units and at all levels of the financial institution 
and service providers.
    {time}  The adequacy of data controls over preparation, input, 
processing, and output.
    {time}  The adequacy of corporate contingency planning and business 
resumption for data centers, networks, service providers and business 
units.
    {time}  The quality of processes or programs that monitor capacity 
and performance.
    {time}  The adequacy of controls and the ability to monitor 
controls at service providers.
    {time}  The quality of assistance provided to users, including the 
ability to handle problems.
    {time}  The adequacy of operating policies, procedures, and 
manuals.
    {time}  The quality of physical and logical security, including the 
privacy of data.
    {time}  The adequacy of firewall architectures and the security of 
connections with public networks.
    In addition to the above, factors such as the following are 
included in the
[[Page 3116]]
assessment of support and delivery at service providers:
    {time}  The adequacy of customer service provided to clients.
    {time}  The ability of the entity to provide and maintain service 
level performance that meets the requirements of the client.
    1. A rating of ``1'' indicates strong IT support and delivery 
performance. The organization provides technology services that are 
reliable and consistent. Service levels adhere to well-defined service 
level agreements and routinely meet or exceed business requirements. A 
comprehensive corporate contingency and business resumption plan is in 
place. Annual contingency plan testing and updating is performed; and, 
critical systems and applications are recovered within acceptable time 
frames. A formal written data security policy and awareness program is 
communicated and enforced throughout the organization. The logical and 
physical security for all IT platforms is closely monitored and 
security incidents and weaknesses are identified and quickly corrected. 
Relationships with third-party service providers are closely monitored. 
IT operations are highly reliable, and risk exposure is successfully 
identified and controlled.
    2. A rating of ``2'' indicates satisfactory IT support and delivery 
performance. The organization provides technology services that are 
generally reliable and consistent, however, minor discrepancies in 
service levels may occur. Service performance adheres to service 
agreements and meets business requirements. A corporate contingency and 
business resumption plan is in place, but minor enhancements may be 
necessary. Annual plan testing and updating is performed and minor 
problems may occur when recovering systems or applications. A written 
data security policy is in place but may require improvement to ensure 
its adequacy. The policy is generally enforced and communicated 
throughout the organization, e.g. via a security awareness program. The 
logical and physical security for critical IT platforms is 
satisfactory. Systems are monitored, and security incidents and 
weaknesses are identified and resolved within reasonable time frames. 
Relationships with third-party service providers are monitored. 
Critical IT operations are reliable and risk exposure is reasonably 
identified and controlled.
    3. A rating of ``3'' indicates that the performance of IT support 
and delivery is less than satisfactory and needs improvement. The 
organization provides technology services that may not be reliable or 
consistent. As a result, service levels periodically do not adhere to 
service level agreements or meet business requirements. A corporate 
contingency and business resumption plan is in place but may not be 
considered comprehensive. The plan is periodically tested; however, the 
recovery of critical systems and applications is frequently 
unsuccessful. A data security policy exists; however, it may not be 
strictly enforced or communicated throughout the organization. The 
logical and physical security for critical IT platforms is less than 
satisfactory. Systems are monitored; however, security incidents and 
weaknesses may not be resolved in a timely manner. Relationships with 
third-party service providers may not be adequately monitored. IT 
operations are not acceptable and unwarranted risk exposures exist. If 
not corrected, weaknesses could cause performance degradation or 
disruption to operations.
    4. A rating of ``4'' indicates deficient IT support and delivery 
performance. The organization provides technology services that are 
unreliable and inconsistent. Service level agreements are poorly 
defined and service performance usually fails to meet business 
requirements. A corporate contingency and business resumption plan may 
exist, but its content is critically deficient. If contingency testing 
is performed, management is typically unable to recover critical 
systems and applications. A data security policy may not exist. As a 
result, serious supervisory concerns over security and the integrity of 
data exist. The logical and physical security for critical IT platforms 
is deficient. Systems may be monitored, but security incidents and 
weaknesses are not successfully identified or resolved. Relationships 
with third-party service providers are not monitored. IT operations are 
not reliable and significant risk exposure exists. Degradation in 
performance is evident and frequent disruption in operations has 
occurred.
    5. A rating of ``5'' indicates critically deficient IT support and 
delivery performance. The organization provides technology services 
that are not reliable or consistent. Service level agreements do not 
exist and service performance does not meet business requirements. A 
corporate contingency and business resumption plan does not exist. 
Contingency testing is not performed and management has not 
demonstrated the ability to recover critical systems and applications. 
A data security policy does not exist, and a serious threat to the 
organization's security and data integrity exists. The logical and 
physical security for critical IT platforms is inadequate, and 
management does not monitor systems for security incidents and 
weaknesses. Relationships with third-party service providers are not 
monitored, and the viability of a service provider may be in jeopardy. 
IT operations are severely deficient, and the seriousness of weaknesses 
could cause failure of the financial institution or service provider if 
not addressed.
    Dated: January 13, 1999.
Keith J. Todd,
Executive Secretary, Federal Financial Institutions Examination 
Council.
[FR Doc. 99-1175 Filed 1-19-99; 8:45 am]
BILLING CODE 6210-01-P, 6720-01-P, 6714-01-P and 4810-33-P

Last Updated 01/20/1999 regs@fdic.gov