Reverse Positive Pay, ACH and international wire blocks, if available in Company’s marketplace, to If NA, PASS protect against unauthorized transactions. Review bank documentation such as monthly account analysis statement or bank positive pay entitlement documentation. Assessment ALTA Best Practices Framework: Assessment Procedure Assessment Recap Procedures Number ALTA Best Practice 3. Overall Assessment Recap: If any Adopt and maintain a written privacy and individual procedure information security plan to protect Non-public marked with an Personal Information as required by local, state asterisk FAILS, Best and federal law. Practice 3 FAILS. 3.01* Obtain the Company’s information security PASS / FAIL program/policy to protect its Non-public Personal If no written Information and verify that the program/policy is procedures, Procedure reviewed and updated at least annually, as 3.01 FAILS. necessary. 3.02* PASS / FAIL Select a sample of 25 employees who have access to Non-public Personal Information (or 100% if fewer than 25 If 20% or more of items employees). Obtain evidence that they were trained in the tested FAIL, Procedure Company’s information security program/policy to protect Non-public Personal Information. 3.02 FAILS
Reverse Positive Pay, ACH and international wire blocks, if available in Company’s marketplace, to protect against unauthorized transactions. Review bank documentation such as monthly account analysis statement or bank positive pay entitlement documentation. If NA, PASS Assessment Procedure Number ALTA Best Practices Framework: Assessment Procedures Assessment Recap ALTA Best Practice 3. Adopt and maintain a written privacy and information security plan to protect Non-public Personal Information as required by local, state and federal law. Overall Assessment Recap: If any individual procedure marked with an asterisk FAILS, Best Practice 3 FAILS. 3.01* Obtain the Company’s information security program/policy to protect its Non-public Personal Information and verify that the program/policy is reviewed and updated at least annually, as necessary. PASS / FAIL If no written procedures, Procedure 3.01 FAILS. 3.02* Select a sample of 25 employees who have access to Non-public Personal Information (or 100% if fewer than 25 employees). Obtain evidence that they were trained in the Company’s information security program/policy to protect Non-public Personal Information. PASS / FAIL If 20% or more of items tested FAIL, Procedure 3.02 FAILS
CFPB%20-%20CTNC%20Presentation%20Materials%209-15-13.docx