As year-end approaches, FedLine® assessment work can quickly become a scramble for control owners. Financial institutions that use FedLine Solutions, i.e., FedLine Web®, FedLine Advantage®, FedLine Command®, and FedLine Direct®, must complete an annual assessment of compliance with applicable security requirements and submit an attestation confirming the assessment was performed. For some institutions, that means managing the work internally; for others, it means bringing in an independent review function or qualified third party.
FedLine assessment and attestation readiness can look different from one institution to the next. Some teams are preparing a self-assessment. Others need independent review support. Many are sorting through findings and deciding what needs attention before attestation.
Start with the path that fits your situation.
What Is Required?
Organizations using FedLine Solutions generally have four responsibilities:
- Conduct an assessment of applicable security requirements
- Complete any required independent review activities
- Submit the required attestation
- Maintain documentation supporting the assessment process
The assessment and attestation are related, but they aren’t the same thing. Organizations perform and document the assessment internally. The attestation confirms that the assessment was completed. Supporting documentation, findings, and remediation plans are typically retained internally rather than submitted with the attestation.
Which FedLine Assessment Path Fits Your Situation?
Path 1: Conducting a Self-Assessment
Some organizations have strong payment operations and established IT controls but have limited time to coordinate the annual review process.
Common challenges include:
- Identifying applicable control requirements
- Gathering supporting evidence
- Coordinating stakeholders across IT, operations, compliance, and risk functions
- Demonstrating that required controls are operating as intended
Organizations conducting a self-assessment often focus on understanding applicable requirements, organizing supporting documentation, and evaluating whether any gaps should be addressed before attestation.
Path 2: Independent Involvement Is Required
Some organizations may be required to involve an independent internal function or qualified third party as part of the Assurance Program process. Federal Reserve guidance covers circumstances in which an assessment must be conducted or reviewed by an independent internal function or qualified third party.1
When independence requirements apply, organizations should focus on:
- Scope clarification
- Assessment methodology
- Documentation review
- Testing support
- Reporting of observations
Early planning can help reduce scheduling pressure as the attestation deadline approaches.
Path 3: Evaluating Findings & Remediation Priorities
A number of organizations complete the assessment process and discover opportunities to strengthen controls, documentation, or governance practices.
Common examples include:
- Incomplete documentation
- Control ownership inconsistencies
- Evidence retention challenges
- Operational procedures that have not been updated alongside technology changes
In these situations, management typically focuses on the significance of identified findings, where remediation may be needed, and which priorities should come first.
What Is Submitted?
One of the most common misconceptions surrounding FedLine assessments involves understanding what should be submitted to the Federal Reserve Banks.
Federal Reserve guidance distinguishes between conducting the assessment and submitting the attestation.2 This distinction can help organizations better organize responsibilities and documentation expectations.
| Submitted to the Federal Reserve Banks | Retained Internally |
|---|---|
| Required electronically signed attestation response confirming the assessment was completed | Assessment records; supporting documentation; testing artifacts; findings documentation; remediation plans |
Who Should Participate?
Successful assessments rarely belong to one department. Often, they involve these roles.
| Role | Typical Contribution |
|---|---|
| IT & Security | Technical controls and supporting evidence |
| Payment Operations | FedLine operational processes |
| Risk & Compliance | Oversight and governance review |
| Internal Audit | Independent perspective when applicable |
| End User Authorization Contacts (EUACs) | Administrative and coordination activities |
| Senior Management | Attestation oversight and decision making |
Bringing stakeholders together early can help reduce delays later in the process.
Four Questions to Ask Before Attestation
Before management signs an attestation, consider the following:
- Have applicable FedLine environments been identified? FedLine environments vary, and organizations should understand which requirements apply to their specific implementation.
- Are control owners clearly assigned? Control ownership should be documented and understood before evidence collection begins.
- Have identified gaps been evaluated? Organizations should understand whether a finding requires remediation, additional documentation, or consideration of compensating controls.
- Does management understand the assessment results? Leaders responsible for attestation should have sufficient visibility into findings and associated risks before signing.
How Forvis Mazars Can Assist With FedLine Assessments
If the questions above are difficult to answer, that may be the signal to get additional support before attestation work becomes urgent. IT Risk & Compliance professionals at Forvis Mazars can help financial institutions understand applicable FedLine requirements, confirm scope, review documentation, review findings, and support the independent attestation process when an independent review is required.
Connect with us today to discuss your organization’s FedLine assessment path.