NCUA LETTER TO CREDIT UNIONS

NATIONAL CREDIT UNION ADMINISTRATION
1775 Duke Street, Alexandria, VA

Date: March 2003

Letter No.: 03-CU-03

TO: Federally Insured Credit Unions

SUBJ: Wireless Technology

The purpose of this letter is to provide important considerations for credit unions that are currently engaged in or may be considering the use of wireless technology.

Wireless technology can potentially provide important benefits for credit unions and their members. For some, this may be a cost-effective alternative for a credit union seeking to expand its existing hard-wired computer network. Additionally, it may enable a credit union to provide members with increased accessibility to its Internet-based financial service offerings.

However, those credit unions that have made a decision to implement wireless technology should also be aware of the potential increase in the amount of risk exposure for the credit union. Credit unions may be able to mitigate the following risk areas with proper planning and controls:

Strategic Risk – A credit union’s ability to meet its strategic goals for wireless technology may be impacted due to:

Transactional Risk – A credit union’s ability to securely deliver wireless services and manage information may be impacted due to:

Compliance Risk – A credit union could face the potential of fines, civil money penalties, payment of damages, contract voidance, and diminished reputation due to violations of, or nonconformance with:

Reputation Risk – A credit union could potentially encounter negative public opinion due to inadequate management of the strategic, operational, and compliance risks outlined above. Adequate management of these risks should reduce the threat of a loss in member confidence in the credit union and/or its wireless services.

NCUA encourages credit unions to review the guidance below to assist with the planning, contracting, implementing, and monitoring of wireless technology.

  1. NCUA Letter to Credit Unions 01-CU-11 Electronic Data Security Overview. This document outlines regulatory requirements and the development and implementation of a security program for electronic data and information systems. The Letter can be obtained via the Information Systems and Technology (IS&T) link found on the Reference page of NCUA’s website, www.ncua.gov.
  2. Attachment to the Federal Deposit Insurance Corporation’s Financial Institution Letter FIL-8-2002 Wireless Networks and Customer Access. This document identifies specific threats associated with wireless technology and related mitigation methods. This information is applicable to credit unions as well as banks. It can be obtained via the Financial Institution Letters link on the FDIC’s website, www.fdic.gov.
  3. The National Infrastructure Protection Center’s (NIPC) “Best Practices for Wireless Fidelity (802.11b) Network Vulnerabilities” publication. This publication is technical in nature and is best suited for those individuals responsible for the technical planning, implementation, and evaluation of wireless. It outlines wireless security issues and related recommendations from the wireless industry. It can be obtained via the “Other Publications” link under the “Publications” link on NIPC’s website, www.nipc.gov.

This NIPC document contains an inactive link to the Wireless Ethernet Compatibility Alliance’s (WECA) Wired Equivalent Privacy (WEP) Security Statement. WECA is now known as the Wi-Fi Alliance. Its recommended security practices can be obtained via the “Design Your Network” and “Secure Wi-Fi” tabs under the “About Wi-Fi” tab on the Wi-Fi Alliance’s website, www.wi-fi.com. Depending on your web browser’s configuration, you may need to navigate the site using the “Site Map” link on the bottom of the main page.

If you have any questions, please contact your NCUA Regional Office or State Supervisory Authority.

Sincerely,

/S/

Dennis Dollar
Chairman