If an examiner asked to see it today, could you? Most programs cannot.
Banks, credit unions, fintechs, lenders, and payments companies operate under the GLBA Safeguards Rule, FFIEC expectations, and whatever your specific examiner will actually test next cycle. The hard part is rarely finding another framework to read. It is proving, on the day an examiner asks, that the program runs the way it says it does.
Bring us the trigger. We will help determine whether you need ongoing leadership, a defined assessment, or a tighter path to evidence.
Passing the last exam is not the same as being ready for the next one.
An examiner wants evidence, not a description.
Walking an examiner through what the program is supposed to do is different from handing over evidence that it actually ran that way this quarter.
One vendor concentration you have never mapped.
Core processing, digital banking, and payments frequently run through the same handful of providers. A single outage or breach at one of them is one point of failure wearing three different vendor names.
The Safeguards Rule assumes a program, not a policy.
A written information security program, a named qualified individual, and access controls tied to risk are baseline expectations now, not best practices to aspire to.
Directors are accountable for oversight they cannot exercise from a status report.
Meeting that responsibility requires risk expressed in terms a director can act on: dollar exposure, accepted risk, and what changes if nothing is done.
Security lives inside the risk function, not beside it.
A financial-services security leader answers to more than one audience. The same control is an operating constraint to the first line, a risk treatment to the second line, something to test for internal audit, and evidence of governance to an examiner or the board.
Keep the service moving.
Product, operations, payments, and lending teams own the process that creates the risk. Controls have to work without turning every change into a governance event.
Show the risk is understood and challenged.
Risk owners, exceptions, control effectiveness, issue aging, and third-party exposure all have to survive credible challenge.
Prove the control actually operates.
Design and operation have to match. Evidence has to be reproducible, and findings have to close, not linger.
Explain what can hurt customers or interrupt critical services.
Leadership needs material scenarios, concentration risk, and resilience described in terms that support a real decision.
The operating consequences are specific to the institution.
Examiners, customers, auditors, and critical providers all create pressure. The underlying expectation is that management knows its material risks, governs third parties, and can demonstrate that controls work.
A critical third party fails on a Monday morning.
The concern is whether customer-facing services continue, recovery objectives are credible, and there is a workable response if the provider cannot perform.
A finding sits open long enough to become a governance problem.
Aging issues, repeat findings, and remediation that keeps slipping can say more about the program than the original gap ever did.
The board gets a dashboard that cannot support a decision.
Vulnerability counts and training-completion percentages do not answer which scenarios are material or where investment changes exposure.
The examiner asks for the evidence behind the conclusion.
Policy, risk assessment, control ownership, testing, and remediation have to connect without reconstructing the story after the request arrives.
“We are regulated, so we already have a security program.”
Regulatory activity produces policies, exam responses, and audit evidence. It does not automatically produce a program that keeps testing itself in the months between exams, when nobody outside the building is watching.
A mature program connects risk, controls, the core provider, privacy, technical reality, and board decisions so the next exam confirms a program that was already running, instead of discovering a gap for the first time.
One of these is ongoing. The other has a due date.
One is a standing responsibility for risk, vendors, and the board. The other is a specific requirement with a date attached. Start with the one you actually have.
You need ongoing security or privacy leadership.
Risk decisions, board communication, vendor oversight, privacy obligations, and program direction are recurring responsibilities that need senior ownership.
Explore Fractional CISO ServicesYou need a defined view of risk or compliance.
A risk assessment mapped to the GLBA Safeguards Rule, a PCI-DSS gap, a privacy assessment, or a third-party risk review can establish where the real exposure sits.
Explore Risk & Compliance AssessmentsThe work changes depending on where the pressure is coming from.
These are existing Neon Clarity services, not industry-specific packages. The industry context changes how we apply them, what gets prioritized, and what evidence matters first.
Fractional CISO
Senior security leadership for exam-facing evidence, board and audit-committee reporting, vendor oversight, and accountability across IT, compliance, and the business.
02Enterprise Risk Assessment
Identify and prioritize material cyber risk mapped to GLBA Safeguards Rule and FFIEC expectations, in terms leadership can act on before an examiner asks first.
03Third-Party Risk Management
Assess vendor risk with particular attention to core banking, payments, and digital banking platforms, where concentration is highest and least visible.
04PCI-DSS Gap Assessment
Evaluate readiness against PCI-DSS requirements and identify gaps affecting cardholder-data security wherever the institution touches card payments.
05Global Privacy Compliance
Assess privacy obligations under GLBA, applicable state privacy law, and customer data-sharing agreements, plus the governance gaps behind them.
06Cyber Risk Quantification
Translate cyber scenarios into the dollar terms a board and audit committee need to meet their own oversight duty under banking law.
Cyber risk is already a business risk here. That is who this is for.
Financial services, fintech, lending, payments, investment, and other organizations handling sensitive financial information.
Operations built on a core banking or payments platform you do not fully control, with cloud services, critical vendors, and real assurance expectations from examiners and customers alike.
Security, IT, risk, compliance, legal, and business owners exist, but ownership or prioritization needs stronger coordination.
An open exam finding, an upcoming FFIEC, NCUA, or state exam, a board question about vendor concentration, a Safeguards Rule gap, or a fintech partner's security incident.
Better security decisions look like fewer surprises at exam time.
Good advisory leaves behind clearer risk ownership, vendor visibility, and board reporting the institution can actually defend when regulators or auditors ask.
Risk becomes easier to prioritize.
Leadership can distinguish material exposure from compliance noise and direct resources toward scenarios that matter most.
Third-party oversight becomes operational.
The core provider and other critical vendors get evaluated for concentration risk, not just a filed questionnaire, with ownership and escalation built in.
Assurance gets less expensive.
Control ownership and evidence processes support exams, customer diligence, and correspondent reviews without rebuilding the same story every time.
Security and privacy stop operating as separate islands.
Data obligations, technical controls, governance, and business decisions are connected where risks overlap.
Board reporting becomes decision-useful.
Executives see exposure, trends, accepted risk, remediation, and investment choices in language that supports governance.
The person advising you is the person doing the work.
No account-manager relay. We work with the systems and people you already have, then make the program clearer, more defensible, and easier to operate.
Start with the business trigger
What changed, who is asking, what is at risk, and what deadline is real? We start with the pressure creating the need, not a canned checklist.
Find out what is actually true
We review the relevant people, process, technology, evidence, commitments, dependencies, and obligations so decisions are based on reality.
Separate requirements from theater
Work is sequenced around material risk, business impact, effort, deadlines, and the operating reality of your team.
Leave with a program your team can run
The goal is more than a report. Your team should understand the decisions, ownership, evidence, and next actions well enough to keep moving.
Advisory should make your team more capable, not more dependent.
You are hiring judgment, structure, and experienced execution, not an indefinite layer between your team and its own security program.
Your advisor is your deliverer. The person shaping the recommendation stays close enough to the work to own whether it is practical.
Recommendations are driven by the problem in front of you, not a product quota or a need to justify a larger managed-services footprint.
Security has to survive contact with business operations, technical constraints, deadlines, customer commitments, and finite capacity.
A defined project can stay a defined project. If ongoing leadership or compliance support later makes sense, the work can evolve without resetting context.
Before you call.
Do you replace our internal risk, compliance, or IT teams?
No. Neon Clarity provides advisory leadership and assessment support while existing teams retain operational ownership.
Can you help with third-party risk beyond questionnaires?
Yes. Effective third-party risk management includes criticality, due diligence, risk decisions, remediation, monitoring, ownership, and escalation.
Can you quantify cyber risk financially?
Yes. Cyber Risk Quantification can translate defined scenarios into financial terms so executives can compare risk, investment, and acceptance decisions.
Can you support PCI-DSS readiness?
Yes. We offer PCI-DSS gap assessment work to identify readiness gaps and remediation priorities.
Can security and privacy work be coordinated?
Yes. Financial data, customer obligations, vendors, security controls, and privacy requirements frequently overlap.
Do you work with fintechs, or only traditional banks and credit unions?
Both. Fintechs face many of the same regulatory and vendor-risk expectations as banks and credit unions, often with less internal capacity built to meet them, which is where this work usually matters most.
Can you help us prepare for an FFIEC, NCUA, or state banking exam?
Yes. Exam readiness work includes control validation, evidence-process design, documentation review, and remediation guidance tailored to the specific exam type and any prior findings.
How is a Fractional CISO different from hiring a security consultant?
A consultant typically delivers a report and moves on. A Fractional CISO holds ongoing accountability for risk decisions, vendor oversight, and board reporting, the same way a full-time CISO would, at a fraction of the cost and commitment.
Do you present findings directly to our board or audit committee?
Yes. Board and executive reporting work is built specifically to translate technical risk into the business and dollar terms a board or audit committee needs to make a decision.
Do you help specifically with the GLBA Safeguards Rule?
Yes. Safeguards Rule expectations, a written information security program, a named qualified individual, and risk-based access controls, are typically addressed through our Enterprise Risk Assessment or ongoing Fractional CISO work rather than sold as a disconnected, separate product.
You do not need another risk register that nobody uses.
Bring us the regulatory pressure, board question, vendor problem, audit finding, or risk decision. We will help turn it into a practical next step.
Bring us the trigger. We will help determine whether the right next step is a focused assessment, ongoing advisory leadership, or something smaller.
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