A Troubling Decline in Cybersecurity: The CFPB's Battle for Protection
In a recent audit report, the Office of the Inspector General (OIG) has revealed a concerning drop in the Consumer Financial Protection Bureau's (CFPB) cybersecurity posture. The report paints a picture of an agency struggling to maintain its security standards amidst a backdrop of resource constraints and controversial government cuts.
But here's where it gets controversial: the CFPB, responsible for safeguarding sensitive data, has seen its infosec program labeled as "not effective." The audit highlights a decrease in maturity from level 4 to level 2, indicating a significant regression in its overall cybersecurity capabilities.
The main issues? Poor maintenance of system authorizations and a failure to establish cybersecurity risk profiles. These profiles are crucial for any organization, as they define the current and desired cybersecurity posture, helping to prioritize security measures. Without them, the CFPB is essentially flying blind, unable to effectively manage and communicate its security objectives.
And this is the part most people miss: cybersecurity risk profiles are not just about identifying risks. They are a tool to ensure an organization's security measures are aligned with its policies, priorities, and requirements. The CFPB's lack of profiles means it's missing a critical piece of the puzzle, making it difficult to assess and improve its security posture.
The OIG's audit found a staggering 35 systems either operating with expired authorizations or completely lacking the necessary authorization process. This is a major red flag, as it means these systems are potentially vulnerable to attacks and data breaches. To make matters worse, the CFPB has been using risk acceptance memorandums (RAMs) as a substitute for proper authorizations, which is not in line with accepted security standards.
RAMs only focus on accepted risks, and while they are part of the authorization process, they are not a replacement for the official ATO (authorization to operate) decision. With RAMs as their only tool for some systems, the CFPB cannot assure the security of these systems or conduct reliable ongoing assessments.
The agency's response to the audit is also worth noting. While they largely agreed with the findings and promised to implement the recommendations, they took issue with the OIG's claim that they have a "lax information security posture." The CFPB argued that many of their systems are low risk and do not contain Bureau data, but the OIG countered that most are moderate risk and some do contain sensitive information.
The resource constraints the CFPB faces are a key factor in this decline. With a reduction in available contractors and staff departures, the agency has lost a significant portion of its infosec program support. This has impacted its ability to effectively maintain cybersecurity activities, especially in areas like continuous monitoring and testing.
The audit's timing aligns with the Trump administration's efforts to reduce the CFPB's workforce by a staggering 90%, a move that has also affected other agencies like the Cybersecurity and Infrastructure Security Agency (CISA). These cuts have reportedly contributed to a dulling of the US' cyber capabilities, leaving the nation more vulnerable to attacks.
So, what does this mean for the future of the CFPB's cybersecurity? With resource constraints and controversial government decisions, the agency faces an uphill battle to regain its security posture. The question remains: Can the CFPB effectively protect sensitive data and restore its infosec program to a level of maturity that ensures the safety of its systems and the public's information? We invite you to share your thoughts and opinions in the comments below.
