SAFE

As we continue to talk about creating a cyber security plan, we have to touch on infrastructure and systems management.The potential privacy impact is assessed when new processes involving personal information are implemented, and when changes are made to such processes (including any such activities outsourced to third parties or contractors), and personal information continues to be protected in accordance with the privacy policies. For this purpose, processes involving personal information include the design, acquisition, development, implementation, configuration, modification and management of the following:

Do you have a plan to combat cyber threats? If you don’t, you need one. And any good plan should include assigning responsibility and accountability for system security. What should this cyber security expert do? Here’s some tips: Any potential system changes should go through this individual and get this person’s approval before the change goes live. You need to assign responsibility and accountability for system changes and maintenance.

The mortgage industry can learn from other industries that are highly regulated and handle a great deal of NPI. Such as, The Life Insurance and Securities industries, which have a significant amount of requirements to comply with compared to any other industries. Agents, Advisors, BGA, BD, Medical Service providers and Carriers handle NPI, PPI, financial, medical, educational information for which they are accountable for. Here are some steps to help your organization build a simple but effective security plan.

The frequency of online attacks against U.S. business continues to increase, along with the cost of defending against those attacks and mitigating any resulting data breaches. Cyber crime now costs a U.S. business $8.9 million per year, an increase of 6% from 2011 and 38% from 2010. Those findings come from the “2012 Cost of Cyber Crime Study,” which was sponsored by security intelligence tool vendor HP and released Monday (10/8/2012) by Ponemom Institute. The businesses profiled in the study also reported that on average, they’re collectively seeing 102 successful attacks per week, up 72 attacks per week in 2011 and 50 attacks per week in 2010.

The key is having a solution that is easy and simple to not only implement, but use for everyone involved in the e-mail transmission. This approach ensures greater traction and compliance. Cyber threats in mortgage affect your entire business. Are you protected? Paperclip’s eM4 protects customers’ personal information from unwarranted access and the accountability for its use. This significantly minimizes your exposure to compliance and reputational risk.

In a presentation titled “Navigating CFPB Investigations and Enforcement Actions” by Jonathan Pompan, Partner, Co-Chair CFPB Task Force, Venable LLP, he asked, “Who is subject to a potential CFPB Investigation? The CFPB authorizes the Bureau to conduct investigations to ascertain whether any person is or has been engaged in conduct that, if proved, would constitute a violation of any provision of Federal consumer financial law. This includes: Banks and Credit Unions, All Mortgage Related businesses, Small-Dollar Lenders, Private Student Lenders, Debt Collectors, Consumer Reporting, Consumer Credit and related activities, Money transmitting, check cashing, and related activities, Prepaid cards, Debt Relief, Financial Advisors, Service Providers, and more…” And that’s not all. Pompan goes on to explain CFPB Investigation and Enforcement Authority, which can lead to significant ramifications. He says, “CFPB may investigate, issue subpoenas and civil investigative demands, and compel testimony. The CFPB may conduct hearings and adjudications to enforce compliance, […]

The Internet has dramatically changed the way we conduct business today. The ability to deliver information, answer questions, and exchange ideas has benefitted all who participate. One significant use of the Internet is electronic mail. The ability to replace letter, fax or phone calls with a simple electronic message has won the day. Storing and quickly retrieving these messages allows organizations to streamline its communications process and by today’s business standards, email has become a cornerstone of every business’ operations.