Carefully consider the risks of wireless technology;
Take appropriate steps to mitigate the risks before deploying either wireless networks or applications.
The Appendix to the FIL is divided into three major parts:
Risks Associated with Wireless Internal Networks
Risks Associated with Wireless Internet Devices
Risks Associated with Both Internal Wireless Networks and Wireless Internet Devices
If your institution utilizes a wireless network or is going to be offering wireless customer access, someone in your institution should study the FIL (even if you aren't a state chartered bank, because it's still solid protective guidance, regardless of your charter type) and formulate a checklist from it of steps to take and points to consider.
FDIC suggests that appropriate steps to mitigate risk could include:
* Establishing a minimum set of security requirements for wireless networks and applications;
* Adopting proven security policies and procedures to address the security weaknesses of the wireless environment;
* Adopting strong encryption methods that encompass end-to-end encryption of information as it passes throughout the wireless network;
* Adopting authentication protocols for customers using wireless applications that are separate and distinct from those provided by the wireless network operator;
* Ensuring that the wireless software includes appropriate audit capabilities (for such things as recording dropped transactions);
* Providing appropriate training to IT personnel on network, application and security controls so that they understand and can respond to potential risks; and
* Performing independent security testing of wireless network and application implementations.
The original version appeared in the January/February 2002 edition of the Oklahoma Bankers Association Compliance Informer.
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