Time for Risk Management

Question:

We have been offering remote deposit capture for nearly two years. The FFIEC guidance issued in January, 2009 says institutions should do a risk assessment first. We didn't. Is it too late?

Answer:

No. The purpose of the risk assessment is to ascertain what risks the activity might pose, assess the likelihood and potential harm for each, and ensure you have sufficient countermeasures in place to guard against what you need to. Unless you do the risk assessment, you don't know whatyou're facing. Do it now.

First published on BankersOnline.com 3/17/09