Elevate your threat defense prowess with our 4-Step approach to meeting FedLine security requirements.
In response to this large, evolving cyber threat landscape, the Federal Reserve Bank announced the Security and Resiliency Assurance Program in October 2020. As part of this program, institutions and service providers that use the FedLine Solutions, including FedLine Web, FedLine Advantage, FedLine Command, and FedLine Direct must:
Conduct an assessment of their compliance with the Federal Reserve Banks’ FedLine security requirements
Ensure that the assessment is conducted or reviewed by an independent internal function or third party, if required by the Federal Reserve Banks,
Develop a remediation plan to address gaps or deficiencies that were identified in the self-assessment,
Submit an attestation that they have completed the assessment
standards including NIST, and relevant supervisory guidance including FFIEC guidance. These standards have stood the test of time and have been effective in guiding organizations to implement robust controls. This assurance program increases confidence that controls are in place and being monitored to protect payment systems and customers. Moreover, the program enhances an organization’s risk management and resiliency focus to help ensure endpoint environments are secure and resilient.
FedLine security review process to encourage holistic risk management practices and risk-based decision making.
discussions and planning to address key risks and develop timely remediation plans for any non-compliance or deficiencies.
Significant increase in customer trust by demonstrating a commitment to maintaining a secure and reliable financial infrastructure.
Identifying gaps and implementing recommended security controls minimizes the likelihood of system outages and security incidents, ensuring uninterrupted flow of financial transactions and contributing to overall operational efficiency.
Identification of areas where security controls can be optimized or streamlined, potentially resulting in cost savings.
BluOcean brings a dedicated FedLine team that has deep knowledge of and experience with the FedLine Assessment Program, and we can effortlessly lead you towards completing your Self-Assessment and Attestation. Our team has an in-depth understanding of various payment rails, and have served the financial services industry for years.
Our extensive experience with testing and reporting on controls, powered by our home-grown customized assessment toolkit will help drive efficiency and quality in your pursuit for meeting FedLine security and resiliency requirements. At BluOcean, we make it our goal to stay up-to-date with the latest security developments, best practices, and emerging trends, guaranteeing that you receive the most accurate and comprehensive evaluation of your compliance efforts.
We understand that every organization is unique, with distinct processes, systems, and risk profiles. That’s why we take a tailored approach to each FedLine assessment, aligning our evaluation to your specific cyber ecosystem. Our experts will work closely with you to identify critical gaps and design recommendations that fit seamlessly within your existing framework.
Our four-step approach is equipped to help you with analyzing the self-assessment program documentation prepared to support your management’s attestation regarding compliance with Federal Reserve Bank (FRB) Operating Circular 5, Electronic Access, and its appendix A (“FRB 5”).
We kick-off with a brief FedLine Security and Resiliency Assurance Program express workshop where we get to know about your risk, controls, policy, processes, and compliance posture
With this information we analyze internal control gaps and either (a) analyze remediation plans documentation identified as a result of the self-assessment program or (b) develop remediation plans for you to mitigate control gaps
With the remediation plan defined, we mobilize our teams to implement solutions to close gaps
The Assurance Program applies to all institutions that utilize a FedLine Solution, either directly or indirectly through a service provider or other agent. These institutions are required to comply with the FedLine policies, procedures and security controls (“Security Requirements”) applicable to their particular electronic connection. The Assurance Program requires that these institutions:
Conduct a self-assessment of their compliance with the Security Requirements. It is a point-in-time assessment, conducted annually.
If required by the Federal Reserve Banks, ensure that the assessment is conducted or reviewed by an independent internal function or third party.
Attest to the Federal Reserve Banks that the self-assessment was completed.
To the extent any deficiencies or gaps were identified in the self-assessment, develop a remediation plan to address such deficiencies.
Some institutions may have elected to outsource some or all of their payment or electronic connection to a third-party service provider. Although the use of third-party service providers is permitted, these outsourcing arrangements do not transfer an institution’s obligations or responsibility for complying with required security measures and controls.
All End User Authorization Contacts (EUACs) should have received the attestation materials associated with their organization’s ABA or RSSD ID on or before March 31, 2022. Your Organization will need to identify a primary point of contact that will coordinate and facilitate the Assurance Program process.
An EUAC or End User Authorized Contact is your organization’s designated point of contact for the Federal Reserve Banks financial services. EUAC have many responsibilities, but one primary responsibility is to ensure that their organization is familiar and complies with the security procedures that are applicable to the FedLine Solutions used by the organization. Yes, you may have more than one.
All institutions (each ABA and RSSD ID) utilizing a FedLine Solution, either directly or indirectly through a service provider or other agent, will need to complete an attestation.
Maybe. When an independent assessment is required, an internal department/function can perform the assessment provided that such internal department/function is independent, such as an internal audit or compliance department (i.e., a function that is not in the reporting line of the senior executive in charge of payment services).
Individual, enterprise or unique solution-specific “risk assessments” may be supporting artifacts and resources leveraged when conducting the self-assessment or completing the attestation. The attestation process is described in the Security and Resiliency Assurance Program Guide.
You should follow your existing remediation processes commensurate with the nature of the identified gap. Your organization is not required to submit the results or findings of your risk assessment, or any supporting documentation, or any remediation plans. The electronically signed attestation response is the only document that will be required to be submitted to the Federal Reserve Banks. Note, however, that evidence of the assessment and any remediation activity should be maintained according to your organization’s record retention policy.
Frequently Asked Questions
Assurance Program Frequently Asked Questions
Resource Center
FedLine Solutions Security and Resiliency Assurance Program Resource Center
Customer Contact Center
Customer Contact Center
Your organization’s attestation is due by December 31 annually. There is no penalty for submitting the attestation early. Going forward, the attestation will need to be completed once per calendar year (January – December).
Failure to submit an attestation by the due date is a violation of Operating Circular 5 that could result in the Reserve Banks taking any of the actions set out in section 7.1 of Operating Circular 5. At their discretion, the Reserve Banks may take other actions including but not limited to disclosing the circumstances of noncompliance to your prudential regulator or other supervisory body, as well as executing limitations on user access and authentications, services, and reporting.
The individual who signs your attestation should be a senior management official or executive officer in charge of electronic payments operations or payments security for your organization.
There is no requirement for a particular number of signers or that signers be different for each FedLine Solution or electronic connection being used. The institution can determine if different signers are appropriate for different solutions for which they have responsibility.
The Federal Reserve Banks determine which organizations will be subject to a standard or independent assessment based on a variety of factors and criteria and these factors may change from time to time. Factors may include, but are not limited to: FedLine Solutions and specific products used, payment volumes and thresholds, and current threat and risk factors. These factors are reviewed and evaluated periodically and may change over time.
If your institution is designated to complete an independent assessment or review, you can find this information in black bold text in the body of the email you received with your Assurance Program materials.
Additionally, your organization’s attestation statement will include terms that your attesting official is asserting that an independent assessment was performed, where required.
Your self-assessment may be completed by your internal staff; however, some organizations may be required to have an independent party conduct or review their self-assessment.
For organizations that have been notified an independent assessment is required (this information is found in the body of your Assurance Program email), the requirement of independence can be satisfied by having:
An independent third party, such as an external audit firm or security consultant, perform the assessment.
An independent internal department/function perform the assessment, such as an internal audit or compliance department (i.e., a function that is not in the reporting line of the senior executive in charge of payment services).
If the assessment was conducted by a non-independent party or function, an independent third party must review the work conducted in connection with the assessment to establish that it was designed and conducted in a manner reasonably sufficient to identify any material noncompliance with the Security Requirements.
At Bluocean, it is our goal to improve your organization’s security posture, while easing the burden of regulatory compliance. Our multidisciplinary team of experts specialize in FedLine assessments and is fully equipped to help you analyze your: self – assessment documentation, information related to design and operation of internal controls identified in the self-assessment program, control gaps, and remediation plans.
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