WOW - we just completed an FDIC exam and the subject had an unusually high priority of scrutiny, more than some safety and soundness areas. A few points (just in case you are facing an examine):

If you grant a loan with no deposit account, make sure that the OFAC is checked.

When you send a wire, make sure that the payee is checked against OFAC and the FBI Control List

GLBA requires documentation in non-computerized areas, as well as computerized areas, e.g. stuff left on desks and other areas that are accessible by the public, screen savers to assure that here is no customer info on the screen

Shredding of discarded documents is important

Thanks for the information. I had heard that the information security portion of GLBA was going to be reviewed.

Also be aware of Allowance for Loan and Lease Losses and Interest Rate Risk.