Reducing the Delta Between New Regulations and Cost-Effective Practices Within the Financial Services IndustryA Study Sponsored By BITS/Financial Services Roundtable |
The purpose of this study is to identify opportunities for financial services industry participants—financial institutions, service providers, industry associations, and regulators—to work more efficiently to achieve timely, practical, and commercially reasonable practices for complying with new regulations and supervisory guidance for technology, security and privacy topics.
This paper was commissioned in December 2008 by BITS, the technology and operations division of the Financial Services Roundtable, and The Financial Services Roundtable’s Anthony T. Cluff Fund. It was conducted by Deloitte & Touche LLP.
To support our analysis, we selected three regulations or guidance to serve as representative examples of the process by which rules are disseminated and addressed by industry participants. These “case studies” include FFIEC Authentication Guidance (2005), FACTA’s Identify Theft Red Flag Regulation (2007), and Interpretive Guidance on Customer Breach Notification in the Gramm-Leach-Bliley Act (2005).
BITS and Deloitte jointly identified three medium to large financial institutions and three “brand name” service providers that would be interviewed by Deloitte. One large insurance company was also identified to provide additional insights from a non-banking perspective. In total we met with approximately twenty-two individuals in fifteen meetings. The conversations were held “on background” and as such the identity of
each participant is not being released. The financial services regulatory agencies declined to participate in the study in an official capacity, and as such we were unable to obtain their perspectives on the perceptions shared with us by the industry participants and on the feasibility of the recommendations.
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Reducing the Delta Between New Regulations and Cost-Effective Practices Within the Financial Services Industry
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