The majority of our clients have now converted to the new FedAdvantage systems and from what we’ve seen these systems are a vast improvement over the old DOS-based Fedline terminals in security and ease of use. But one of the most common questions we now get is:
Can you help us with what are the new regulatory requirements for the FedAdvantage systems?
Well, to date, there hasn’t been any guidance from the FFIEC conglomerate but we have gotten some word that it is coming. So we decided to put together a top 5 list of things that you should start beginning to do to get in compliance with Fedline Advantage:
1) Separation of Duties – The old LA (local administrator) of the Fedline DOS is now replaced by what the Fed is calling an EUAC (End-user Administration Control). The main concern is the same as it was with the old system, the EUAC should not be one of the people that are doing any of the daily wire or ACH activities.
2) Securing USB Keys – Now everyone that has access to the FedAdvantage system has to login with a USB key attached to the system. Examiners are looking to be sure that those USB keys are locked up and not left out when not at the system, whether for lunch or at the end of the day. We’ve advised our clients to keep them in either a locked drawer or box.
3) Tracking paperwork is still necessary – The new system can kept track of all transcations directly on the system, which is great for research purposes, but be sure you still keep track of all your print outs in a secured environment and, until further guidance is given, for at least 5 years.
4) Figure out your backup options – Yes, you now can install the software on any machine in your office and you’re not locked down to one machine but, what if the power goes out? Where are you going to go? Many banks are establishing a partnership with other banks that are running FedAdvantage to allow them to use their facilities in case of emergency. And I probably don’t have to say but, be sure to update this in your BCP/DR plans!
5)Update your policies/procedures – Finally, now that the conversion has taken place make sure that all your policies and procedures have been updated to use the new FedAdvantage verbiage with updated screenshots if necessary. (It’s picky, I agree, but it has to be done.)
I want to say again that this list is just some of the major items of the FedAdvantage system that we’ve seen examiners mention already. I’m sure there will be more of it but we wanted to give you a head start on these items so you’ll be well on your way to compliant when the guidelines are official.
