2014 Vol. 98 No. 6

18 HќќѠіђџȱ юћјђџ Ѣћђȱ2014 23(5$7,216 7(&+12/2*< Financial institution professionals and their cardholders, as well Šœȱ–Ž›Œ‘Š—œȱŠ—ȱ˜‘Ž›ȱꗊ—Œ’Š•ȱ services organizations, are understandably on edge these days. ŽŒŽ—ȱ‘’‘Ȭ™›˜ę•Žȱ™˜’—Ȭ˜ȬœŠ•Žȱ security breaches have revealed a pressing need to reevaluate card security. While the investigations into the breaches will likely sharpen defenses in the future, now is the ’–Žȱ˜ȱ™•Š—ȱ˜›ȱ‘Žȱ—Ž¡ȱŒ¢‹Ž›ȱŠĴŠŒ”ǯ The Threat Landscape Fraudsters have proved to be intelligent, coordinated, strategic Š—ȱœŽŠ•‘¢ǯȱ ‘Žȱ—˜—™›˜ęȱ ›’ŸŠŒ¢ȱ Rights Clearinghouse calculates ‘Šȱ‹žœ’—ŽœœŽœǰȱ’—Œ•ž’—ȱꗊ—Œ’Š•ȱ institutions and retail outlets, have reported 1,571 breaches involving 470 –’••’˜—ȱŒžœ˜–Ž›ȱꗊ—Œ’Š•ȱ›ŽŒ˜›œȱ over the past nine years. ‘ŽœŽȱŠĴŠŒ”œȱŠ›Žȱ—˜ȱ˜™™˜›ž—’œ’ŒDzȱ they are the result of deliberate Žě˜›œȱŠ—ȱ•˜—ȬŽ›–ȱ™•Š——’—ǯȱ Ÿ’Ž—ŒŽȱœžŽœœȱ‘Žȱ‹›ŽŠŒ‘Žœȱ last holiday season probably were launched much earlier in the year, with hackers compromising systems, exploring how much they could do without being detected, then waiting patiently for a convenient moment to exploit their plan. The risk of similar events will continue to challenge the ‹Š—”’—ȱ’—žœ›¢ǰȱŠ—ȱꗊ—Œ’Š•ȱ institutions can expect increased scrutiny of everything, ranging from the standards and practices of technology service providers and their core processors to the type of payment cards issued. Third-party risks were already in the crosshairs of regulators prior ˜ȱ‘Žȱ‹›ŽŠŒ‘Žœǰȱ ’‘ȱ‘Žȱ ĜŒŽȱ˜ȱ the Comptroller of the Currency issuing updated guidance for banks to shore up defenses by improving their vendor management programs. ’”Ž ’œŽȱ‘Žȱ™žœ‘ȱ˜ Š›ȱ‘Žȱ Șȱ standard has been boosted by the breaches. Time for Planning A fraud incident response plan is an essential tool that can provide structure and rational thinking during the stress and anxiety that accompany these types of events. —¢ȱꗊ—Œ’Š•ȱ’—œ’ž’˜—ȱ‘Šȱ˜Žœȱ not have a formalized plan in place should consider developing one as part of its risk management process. During the chaotic and emotional response to recent holiday breaches, it was easy to distinguish between ‘Žȱꗊ—Œ’Š•ȱ’—œ’ž’˜—œȱ‘Šȱ‘ŠȱŠȱ plan in place — and had rehearsed these situations — from those that did not. A plan takes into account the trying conditions that accompany a fraud incident, and ™›˜Ÿ’Žœȱ‘Žȱꗊ—Œ’Š•ȱ’—œ’ž’˜—ȱ with a framework for making critical business decisions. ȱ œœŽ—’Š•ȱŽ•Ž–Ž—œȱ˜ȱŠȱ›Šžȱ incident response plan include: % ›˜ę•Žœȱ˜ȱ›Š—œŠŒ’˜—Ȭ•ŽŸŽ•ȱ activity to aid in the rule strategy development process; % Contact information for all process participants, including internal and external departments, vendors, decision-makers, approvers, etc. Planning Now Can Limit Future Data Breach Losses яќѢѡȱѡѕђȱ Ѣѡѕќџ Eric Lillard is vice president of fraud and operations for PULSE, a Discover Financial Services company headquartered in Houston. He joined the company in 2010 and is accountable for delivering fraud miti- Š’˜—ȱœŽ›Ÿ’ŒŽœȱŠœȱ™Š›ȱ˜ȱ‘Žȱ ȱ Ž‹’ ›˜ŽŒ® ™›˜žŒȱœž’Žǯȱ ›ŽŸ’˜žœ•¢ȱ ’••Š›ȱ ˜›”Žȱ˜›ȱ ŠœŽ›- Š›ȱ ˜›• ’Žȱ˜›ȱŗŗȱ¢ŽŠ›œȱŠ—ȱ˜›ȱ ¢Œ›˜ȱ —ŒǯǰȱŠ—ȱ information security consultancy. He earned a bachelor’s degree from Southern Illinois University and is ™ž›œž’—ȱŠȱ–ŠœŽ›ȂœȱŽ›ŽŽȱ›˜–ȱ ’œœ˜ž›’ȱ ŠŽȱ —’ŸŽ›œ’¢ǯȱ ‘ŽȱŠž‘˜›ȱŒŠ—ȱ ‹Žȱ›ŽŠŒ‘ŽȱŠȱŞřŘȬŘŗŚȬŖŗŘŜǰȱŽ–Š’•DZȱŽ›’Œ•’••Š›ȓ™ž•œŽ—Ž ˜›”ǯŒ˜–ǯȱ ȱ’œȱ an associate member of the Indiana Bankers Association.

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