Financial Services / SOC 2 + FFIEC
SOC 2 + FFIEC back-to-back. Zero findings.
A regional community bank with $4.2B AUM, 42 branches, and a digital-banking platform they were actively growing. The prior two audit cycles had surfaced control-operation deficiencies. The Chief Risk Officer needed the next cycle clean, and she needed it without her team burning six weekends to get there.
The problem
Each year's SOC 2 Type II and FFIEC CAT cycles were consuming 14-16 weeks of senior IT and compliance leadership time. Evidence collection always happened in the weeks right before each audit. Log samples pulled from memory, access reviews reconstructed late, vendor questionnaires tracked down one at a time. Two cycles in a row had surfaced operating deficiencies in change management and user access reviews. The regulator was starting to take notice, and so was the board.
The engagement
- Week 1-3: Controls gap assessment mapped to Trust Services Criteria and FFIEC CAT. SSP and control matrix rebuilt. Prior-year deficiency remediation designed.
- Week 4-6: Privileged Access Management deployed. Just-in-time access with session recording for admins, core banking operators, and trading desks. User access reviews automated on a quarterly rhythm.
- Week 7-10: 24/7 SOC cutover with financial-services threat intel. SIEM tuned for BEC, wire-fraud patterns, credential abuse, and insider threats. Detection content mapped to FS-ISAC advisories and MITRE ATT&CK techniques active in financial services.
- Week 11-14: Continuous evidence pipeline operational. Automated collection of change records, access reviews, training completion, incident history, vendor assessments. Quarterly readiness reviews scheduled with compliance.
- Ongoing: Monthly executive review. Quarterly FFIEC CAT maturity assessment. Annual tabletop exercise with executive team. Every control has a named owner and documented operation evidence.
The outcome
“Two consecutive clean audits, SOC 2 Type II and FFIEC CAT, for the first time in five years. The examiners asked for evidence and my team handed it over in the meeting instead of promising to follow up.”
— Chief Risk Officer, regional community bank
- Zero findings on SOC 2 Type II in the first post-engagement cycle
- Zero findings on FFIEC CAT maturity assessment, up from 3 deficiencies the prior year
- Audit preparation effort down 55%. Dropped from 14-16 weeks of leadership time to 6-7 weeks.
- Two attempted BEC campaigns detected and contained within 30 minutes. Zero wire loss.
Voices from the engagement
Additional perspectives from the same engagement across different roles.
“SOC 2 Type II and FFIEC CAT back-to-back with zero findings was not something I expected this decade. Two years of operating deficiencies closed out, and the examiners noted the evidence quality directly in their out-brief.”
— Chief Compliance Officer, regional community bank
“Evidence generation used to be a fire drill every quarter. Now it runs continuously. When the auditor requested change-management samples, I exported a quarter of records in under 10 minutes with full reviewer approvals attached.”
— VP of Internal Audit, regional community bank