Pub. 3 2013-2014 Issue 6

12 O V E R A C E N T U R Y : B U I L D I N G B E T T E R B A N K S - H E L P I N G C O L O R A D A N S R E A L I Z E D R E A M S  Cloud Computing | continued on page 14 C loud computing promises lower ad- ministration costs, flexible disk space, and on-demand computing power. But can it meet the data security require- ments of banks and other financial institutions? Cloud computing has received a lot of buzz in industry circles under the premise that it can decrease the costs associatedwith admin- istering an on-site system. It promises cheap, on-demand, and elastic processing power, disk storage, and memory. But is cloud com- puting a good option for financial institutions? As with any complicated question, it de- pends—both onwhat systems you’re consider- ing relocating to the cloud and what type of data will be processed, stored, or transmitted by the cloud service provider on your behalf. Given the myriad of banking regulations, data security is paramount. It’s crucial to consider regulations noted in the Federal Financial Institutions Examination Council’s Outsourcing Technology Services Booklet, federal and industry regulations around protecting personally identifiable information (Red Flags Rule) and payment card data (the Payment Card Industry Data Security Stan- dard), and the information security portions of the Gramm-Leach-Bliley Act. And yet, with due diligence, cloud comput- ing could still be a solid choice for financial institutions seeking computing power and the ability to scale quickly as business grows while working with limited IT budgets. Choosing a Deployment Model Before jumping on the cloud computing bandwagon, consider what deployment model will work for your organization: private, pub- lic, or hybrid. Private clouds belong to a single organiza- tion. While they’re themost expensive option, they provide the best balance of flexibility and security. Public clouds (like those provided by Amazon’s Elastic Compute Cloud, Microsoft’s Azure, and Google’s Compute Engine) have a low initial cost and a low entry barrier, but you relinquishmuch control over the security of your data. “Cloud computing could still be a solid choice for financial institutions seeking computing power and the ability to scale quickly as business grows while working with limited IT budgets.” FEATURE ARTICLE FRANCIS TAM PARTNER, MOSS ADAMS LLP Cloud Computing: Good for Banks?