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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
12 CFR part 30, appendix D (OCC Heightened Standards) Large institution governance Supports compliance with enhanced governance requirements

Next Steps