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Control 3.13: FFIEC IT Examination Handbook Alignment — Verification & Testing

Test cases and evidence collection procedures to validate alignment with FFIEC IT Examination Handbook requirements.

Test Cases

Test 1: Control-to-Booklet Mapping Completeness

  • Objective: Verify that all FFIEC examination booklet areas are mapped to Copilot governance controls
  • Steps:
  • Review the Compliance Manager assessment for FFIEC IT Examination mapping.
  • Verify each FFIEC booklet (Audit, Information Security, Management, Operations, Development) has mapped controls.
  • Confirm no booklet areas relevant to Copilot are unmapped.
  • Validate that each mapped control has associated evidence and improvement actions.
  • Expected Result: All relevant FFIEC booklet areas have mapped Copilot governance controls with evidence.
  • Evidence: Assessment mapping report showing booklet-to-control alignment.

Test 2: Audit Trail Completeness

  • Objective: Confirm that audit trails meet FFIEC Audit Booklet requirements for Copilot activities
  • Steps:
  • Generate the FFIEC Audit booklet evidence collection (Script 1).
  • Verify audit logs capture: administrative changes, user interactions, security events, and compliance violations.
  • Confirm retention periods meet FFIEC expectations (5+ years).
  • Test audit log search and retrieval within the examiner response time target.
  • Expected Result: Audit trails are comprehensive, retained appropriately, and retrievable within target timeframes.
  • Evidence: Audit log exports covering all required event categories.

Test 3: Mock Examination Exercise

  • Objective: Validate examination readiness through a simulated FFIEC IT examination
  • Steps:
  • Have an independent team (internal audit or external consultant) conduct a mock examination.
  • Provide the examination team with simulated examiner requests covering all FFIEC booklet areas.
  • Measure response time, evidence quality, and completeness for each request.
  • Document findings and remediation items from the mock examination.
  • Expected Result: Mock examination completed with all requests fulfilled within target timeframes and acceptable evidence quality.
  • Evidence: Mock examination report with scores, findings, and remediation recommendations.

Test 4: Examination Response Time Validation

  • Objective: Verify that the organization can respond to examiner requests within the target timeframe
  • Steps:
  • Create a set of 10 simulated examiner requests covering various Copilot governance areas.
  • Time the response from request receipt to evidence package delivery.
  • Verify all responses are delivered within 48 hours (regulated target).
  • Assess the quality and completeness of each response package.
  • Expected Result: All 10 simulated requests are fulfilled within 48 hours with complete, accurate evidence.
  • Evidence: Response time log and quality assessment scores.

Evidence Collection

Evidence Item Source Format Retention
Control-to-booklet mapping Compliance Manager PDF/Export With assessment
Audit trail completeness report PowerShell CSV/Text 7 years
Mock examination report Assessment team PDF With assessment
Response time metrics Time tracking Spreadsheet With assessment

Compliance Mapping

Regulation Requirement How This Control Helps
FFIEC IT Examination Handbook Cross-booklet IT governance Supports comprehensive alignment with FFIEC examination expectations
FFIEC CAT Cybersecurity maturity assessment Helps meet maturity level requirements for AI technology governance
OCC Heightened Standards Large institution governance Supports compliance with enhanced governance requirements

Next Steps