Warnings About Financial Institutions and Derivatives

Risks of Financial Institutions
The nature of a financial institution is that there are a lot of ways to go to hell in a bucket. You can push credit too far, do a dumb acquisition, leverage yourself excessively---its not just derivatives [that can bring about your downfall].

Maybe it's unique to us, but we're quite sensitive to financial risks. Financial institutions make us nervous when they're trying to do well.

We're exceptionally goosey of leveraged financial institutions. If they start talking about how good their risk management is, it makes us nervous.

We fret way earlier than other people. We've left a lot of money on the table through early fretting. It's the way we are -- you'll just have to live with it.

Derivatives
The system is almost insanely irresponsible. and what people think are fixes aren't realy fixes. It's so complicated I can't do it justice here - but you can't believe the trillions of dollars involved. You can't believe the complexity. You can't believe how difficult it is to do the accounting. You can't believe how big the incentives are to have wishful thinking about values and wishful thinking about ability to clear.

People don't think about the consequences of the consequences. People start by trying to hedge against interest rate changes, which is very difficult and complicated. Then, the hedges make the [reported profits] lumpy. So they use the new derivatives to smooth this. Well, now you've morphed into lying. This turns into a Mad Hatter's Tea Party. This happens to vast, sophisticated corporations.

Somebody has to step in and say, "We're not going to do it - it's just too hard."

I think a good litmus test of the mental and moral quality at any large institutions [with significant derivative exposure] would be to ask them, "Do you really understand your derivatives book?" Anyone who says yes is either crazy or lying.

It's easy to see [the dangers] when you talk about [what happened with] the energy derivatives - they went kerflooey. When [the companies] reached for the assets that were on their books, the money wasn't there. When it comes to financial assets, we haven't had any such denouement and the accountings hasn't changed so the denouement is ahead of us.

Derivatives are full of clauses that say if one party's credit gets downgraded then it has to put up collateral. It's like margin - you can go broke [just putting up more margin]. In an attempt to protect themselves, they've introduced instability. Nobody seems to recognize what a disaster of a system they've created. It's a demented system. 

In engineering people have a big margin of safety. But in the financial world, people don't give a damn about safety. They let it balloon and balloon and balloon. It's aided by false accounting. I'm more pessimistic about this than Warren is.

Accounting for Derivatives
I hate with a passion GAAP [Generally Accepted Accounting Principles] as applied to derivatives and swaps. JP Morgan sold out to this type of accounting to front-end revenues. I think it's a disgrace.

It's bonkers, and the accountants sold out. Everyone caved, adopted loose [accounting] standards, and created exotic derivatives linked to theoretical models. As a result, all kinds of earnings, blessed by accountants, are not really being earned. When you reach for the money, it melts away. It was never there.

It [accounting for derivatives] is just disgusting. It is a sewer, and if I'm right, there will be hell to pay in due course. All of you will have to prepare to deal with a blowup of derivative books.

Likelihood of a Derivatives Blowup
We tried to sell Gen Re's derivatives operations and couldn't, so we started liquidating it. We had to take big markdowns. I would confidently predict that most of the derivatives books of [this country's] major banks cannot be liquidated for anything like what they're carried on the books at. When the denouement will happen and how severe it will be, I don't know. But I fear the consequences could be fearsome. I think there are major problems, worse than in the energy field, and look at the destruction there.

I'll be amazed if we don't have some kind of significant [derivatives-related] blowup in the next five to ten years.

I think we're he only big corporation in America to be running off its derivative book.

It's a crazy idea for people who are already rich -  like Berkshire - to be in this business. It's a crazy business for big banks to be in.

Yo would be disgusted if you had a fair mind and spent a month really delving into a big derivative operation. You would think it was Lewis Carroll. You would think it was the Mad Hatter's Tea Party. And the false precision of these people is just unbelievable. They make the worst economics professors look like gods. Moreover, there is depravity augmenting the folly. Read the book F.I.A.S.C.O., by law professor and former derivative trader Frank Partnoy, an insider account of the depravity of derivative trading at one of the biggest and best-regarded Wall Street firms. This book will turn your stomach.

The scannable card serves as proof that a background check has been performed and it contains features aimed at preventing misuse. In addition to a photograph, the card contains a smart chip that carries a copy of the holder's fingerprint. Port and delivery workers, cargo handlers, and other employees who must venture into sensitive or secure areas will be required to submit to a fingerprint scan before entering those locations. The scanning machine will automatically perform a match analysis with the fingerprint embedded in the smart chip.

This is a great application for these cards.

Today, allow me to update you on FAIR and the movement towards a formal, open standard.  There’s a couple of cool things going on in our little risk-world.

First, The Open Group Security Forum continues to move towards a formal adoption of FAIR.

WHAT DO YOU MEAN “WE” - YOU GOT A STANDARDS BODY IN YOUR POCKET OR SOMETHING?

Our meeting in Chicago a few weeks ago was great, but also slightly disturbing for me. I got pronoun-confusion syndrome.   I’m used to using the “we” pronoun to refer to RMI, or Jack and myself as we vet the models.  So without even thinking I would said “we have been looking at how loss occurs, and may want to change the model some” and The Open Group Members freaked out (rightfully so).  Adrian Seccombe gently reminded me that the “we” was now the Security Forum, and that “we” didn’t go changing things at will without vetting against each other.  Man I love this stuff.  I get to run our thoughts and ideas past some great folks now - you know, those smart people who tend to have really complex problems and are trying hard to solve them.

Formal Adoption:  Soon, Very Soon Now

Formal Adoption basically means we’ve made this document, everyone is close to saying that they generally like it, and once that finally happens then “bam”, we’re ready to move onward and upward with better things (see Cookbooks, below).  We’ve got a couple of changes to the current document that have been requested that aren’t a big deal.  For example, one request is that we make some statement about general applicability of FAIR to risk domains outside of the IT realm.   But once additions like that and others are done, this long process should be complete.

New Document Moving Towards Public Release:

We’ve got a basic document that should be public in the next few weeks on “What Makes a Good Risk Assessment Methodology” - written by yours truly and Jack.  It’s a very high-level document, and serves two purposes:

• For novices it helps parse out what is important in any undertaking to understand corporate risk (the repeated discussions on the ISO 27001 mailing list make me think it would be a place ripe for such a document).
• For those who “know” risk, it helps to re-establish some fundamental principles like the use of scales (ratio, please), the implications of dealing in probabilities, what attributes like consistency and defensibility mean, how “risk” should be reported to the business (something you know, meaningful) and so on.

When this doc is deemed ready for public consumption I’ll be sure to post on this blog here.

COOKBOOKS, EUROPEAN AGENCIES, AND, IRON CHEF “RISK” - WHOSE CUISINE WILL REIGN SUPREME?

One interesting thing that came up in the Chicago meeting was that ENISA (The European Network and Information Security Agency) developed a very nice document that reviewed something like 18 different risk assessment methodologies against their Criteria for Goodness.  FAIR was one of the ones they reviewed, and we (the royal “we” used there to include all us FAIR-Folk) did awfully well.  Things of interest:

1. They based their work on the current introduction paper which is not at all a step-by-step guide towards an organizational risk assessment (what ENISA really wanted) and we did pretty well.  Well enough that if we had developed a paper along the lines of NIST 800-30 or OCTAVE for the use of FAIR in a formal process, we could have done really, really well.  Like won-the-bake-off kind of well.
2. FAIR is actually not at all incongruous to many of the risk assessment methodologies offered, and in fact compliments many of them by letting those methodologies develop real, structured probabilities.  Think OCTAVE, where they basically say “math is (probabilities are) hard, so if you want to do them for reals, good luck!  But here’s a nonsensical way to do things if you want to believe in magic-fairy risk“.  FAIR fits right in there by stomping on the magic-fairy risk with the jack-boots of rationality.  FAIR similarly helps other risk standards that might lack structured probability development.

So The Open Group Security Forum decided that though we could create a new document and totally p0wn any future ENISA bake-off, there wasn’t much demand for the development of that documentation by the membership  - a point which was made quite apparent at the beginning of the discussion when one large European company CISO asked “What’s ENISA?”  Relevancy is everything, I suppose.

But that second item up there - the one about helping rather than competing with other “risk assessment methodologies” - really struck a chord.  So “we” (The Security Forum) are going to develop some “Cookbooks” that basically are high-level documents that say “If you want to use FAIR with (OCTAVE/COSO/CoBIT/Whatever) here’s how it fits, makes it better, and improves your life.  I’m pretty excited about these, and our first document looks like it’s going to be COSO integration.

THE OPEN GROUP SECURITY FORUM - THEY’RE A TRUSTING BUNCH (WITH QUALIFICATION, OF COURSE)

Finally, many people have asked me “Why work with The Open Group?”  There are many reasons, to be sure, but I will give you one example.  Members of the Security Forum there are not only great at vetting the model and getting consensus on risk and risk factors - but they’re quick to start applying.  So in Chicago, I thought I’d be talking about FAIR and the standard and fighting groupthink.  Nope.  Not at all.  In fact, the forum members spent more time suddenly discussing use of FAIR in a new Trust Model they’re developing.  So all of the sudden, I’m part of a new and exciting project to develop a Trust Model - how cool is that?  While formal adoption of the Trust Model will be necessarily long and deliberate - the collaboration and development is happening much faster than I can keep up with.  But if you all will allow me, it will help me get my head around it all by blogging about it later this week.  So be prepared to read about me dealing in “Trust” a little bit.

In particular, SSL certificates (as used to identify https websites) might contain one of these weak keys — and so it would be possible for an attacker to successfully impersonate a secure website. Of course the attacker would need to persuade you to mistakenly visit their site — but it just so happens that one of the more devastating attacks on DNS has recently been discovered; so that’s not as unlikely as it must have seemed back in May.

Anyway, my old friend Ben Laurie (who is with Google these days) and I have been trawling the Internet to determine how many certificates there are containing these weak keys — and there’s a lot: around 1.5% of the certs we’ve examined.

But more of that another day! because earlier this week, Ben spotted that one of the weak certs was for Sun’s “OpenID” website, and that two more OpenID sites were weak as well (by weak we mean that a database lookup could reveal the private key!)

OpenID, for those who are unfamiliar with it, is a scheme for allowing you to prove your identity to site A (viz: provide your user name and password) and then use that identity on site B. There’s a queue of people offering the first bit, but rather less offering the second : because it means you rely on someone else’s due diligence in knowing who their users are — where “who” is a hard sort of thing to get your head around in an online environment.

The problem that Ben and I have identified (advisory here), is that an attacker can poison a DNS cache so it serves up the wrong IP address for openid.sun.com. Then, even if the victim is really cautious and uses https and checks the cert, their credentials can be phished. Thereafter, anyone who trusts Sun as an identity provider could be very disappointed. There’s other attacks as well, but you’ve probably got the general idea by now.

In principle Sun should make a replacement certificate and that should be it (and so they have — read Robin Wilton’s comments here). Except that they need to put the old certificate onto a Certificate Revocation List (CRL) because otherwise it will still be trusted from now until it expires (a fair while off). Sadly, many web browsers, and most of the OpenID codebases haven’t bothered with CRLs (or they don’t enable their checking by default so it’s as if it wasn’t there for most users).

One has to conclude that Sun (and the other two providers) should not be trusted by anyone for quite a while to come. But does that matter ? Since OpenID didn’t promise all that much anyway, does a serious flaw (which does require a certain amount of work to construct an attack) make any difference? At present this looks like the modern equivalent of a small earthquake in Chile.

Formalize your Final Security Review (FSR) Process

A Final Security Review is your final security audit to ensure your software is secure enough to deliver to your customers. I will assume the idea of an FSR is a new concept and try to provide some FAQ-style detail on this topic.

Who is the FSR team? An FSR Team usually consists of a non-product-team security expert (for impartial perspective), a security representative from the product team, and individual representatives from the separate disciplines. However, that size team may not scale to your company. If that is the case, at a minimum, you should have an impartial “outsider” separate from the product team who understands the security requirements as well as the measurements used to validate them. This person along with a project manager can probably perform the bulk of the FSR with development or test leadership providing input as needed.

What is needed to do an FSR? All threat models should be revised to reflect the final product, the code should be complete, and all security-related testing should be completed and documented. In addition, everyone involved in the FSR should have full access to the bug database to review status or exceptions to security bugs.

What does an FSR team do?

1. Re-review threat models to verify all mitigations identified in those exercises were fixed or went through an exception process.
2. Verify that all security issues uncovered during the development process were fixed or granted exceptions by the appropriate people. This is where you verify whether the state of your security bugs meets the “bug bar” requirements you have defined for your products.
3. If there is any output from security tools that you have used to define requirements, the FSR team would verify that the results of the tools meet the security requirements.
4. Review all exceptions to verify that they approve these decisions in the context of the final product. If they identify risks associated with the exceptions, they should communicate those to the business ownership for a final decision before signoff. Any decisions related to known risks should also be reflected in the response plan for future reference.
5. Finally, there should be a final signoff exercise where all security people and project leadership jointly approve the decision of the Final Security Review.

How long does an FSR take? If done correctly, the FSR will likely take some time. You should schedule this review well in advance of your release date to give your FSR team some time to complete the review, push issues back to the product team, and respond to any serious issues that may be discovered.

Final security reviews are a crucial piece to your Security Development Lifecycle. It would be easy to encourage secure development in your team, but as you expand your process to include formal security requirements and begin enforcing those requirements, it is necessary to perform a final audit of your product before it is released. Your customers will thank you for taking the time to add this layer of quality control to your operations and you will likely save yourself some security embarrassment down the road by adding a FSR to the end of your product cycle.

Document security work for reference

After the FSR is complete, there is still work for the security team. The final FSR documentation should be archived along with the symbols and code that represents the finished project. This becomes the time-stamped “snapshot” of your product. Your post-release process should include archiving the following documents in an easily accessible location:

·         All final threat models for future reference.

·         Bug bars, tool settings, and test results related to your project and the supporting tools used to validate. These will be referenced and reused in the next product cycle.

·         All documented security bug exceptions. These need to be rolled into your next product cycle to ensure they are addressed.

·         The final symbols that reflect the product shipped should be archived.

·         The Final Security Report and project signoffs to validate your security audit activity

·         Your Incident Response Plan (discussed in the Crawl post). This must be accessible for quick reference if security incidents occur.

Archiving this evidence serves a few critical purposes: it shows historic evidence of the work you did to ensure a secure product, allows you to postmortem the results and improves your process each time, and reduces the amount of time your team will have to spend next time around by making the existing resources reusable.

In closing…

I hope this long series has provided some practical steps you can take to move your Security Development Lifecycle practices to the next level. At Microsoft, creating a lifecycle to match security development practices has faced a fair share of challenges. However, the investment and time has resulted in more secure products. We’ll continue refining how we execute the Security Development Lifecycle and hope to share those ideas with you along the way. We welcome your thoughts and questions as you start “Walking” with the SDL in your own company and look forward to seeing more secure products and customers as a result.

I’ve created a unique tag on the SDL Blog to cover this series. To get a full list of the related posts, click the “Crawl Walk Run” tag on the left column. I’ll post a Word document version of the full “Walk” series sometime in the next week.

Dan Munz, project manager of the Collaboration Project commented on the unique work that the National Academy of Public Administration (NAPA) is doing to bring together government leaders. The Collaboration Project seeks to innovate across government not just down the silos and create a safe place for leaders to have discussions around innovation.

ScienceLogic: What is the National Academy of Public Administration?

Dan Munz: The Academy is an independent, non-partisan, non-profit organization dedicated to tackling government’s most complex challenges. We were founded in 1967 by James Webb, the NASA administrator who took us to the moon – he saw that he could consult the National Academy of Sciences for expert technical advice, but had no counterpart in government for expert management advice. That’s been our mission ever since.

ScienceLogic: What is the Collaboration Project? How long has it been around?

Dan Munz: The Collaboration Project is the Academy’s response to two parallel trends we see in government. The first is the government’s need to transform the way it does business. There is a strong demand for change out there driven by a number of challenges that are forcing the government to rethink its mission and structure. Challenges include a public disconnected from government; a multi-sector workforce and increasing reliance on contractors; financial instability; and new types of security threats, just to name a few. More and more, the challenges facing government reach across the traditional boundaries of agency and mission. But government isn’t configured to work that way.

The second trend is the unprecedented opportunity collaborative technology offers to drive transformational change in government. Tools like blogs, wikis, and mashups are changing the way leaders think about problems. They’re focusing not on what they can do just within their offices or agencies, but what voices they need to pull together across government, non-profits, the general citizenry, and other stakeholders to solve these problems. The Collaboration Project’s goal is to encourage this type of thinking and empower leaders committed to use collaborative technology to:

• strengthen citizen civic engagement;
• enhance government transparency;
• improve service delivery and operational efficiency; and
• facilitate coordination and innovation within and between agencies.

ScienceLogic: Why focus on Web 2.0 in the government?

Dan Munz: The question of how web 2.0 will impact federal IT departments is a critical one. Our view is that “the era of big systems” is basically over. Things like disk space, bandwidth, and computing power are basically shifting from being assets to being commodities.

There’s also a shift in expectations. People both inside and outside government – especially Gen-X and Gen-Y – are incredibly frustrated by being able to use lightning-fast apps like Flickr, YouTube, and Facebook that don’t even live on their hard drives while the government and other large organizations still operate clunky PCs, space-limited e-mail accounts, and sluggish e-mail servers.

So aside from the opportunity for transformative leadership, the idea of web 2.0 at a government level is very appealing in terms of getting the most out of the IT infrastructure we already have, rather than embarking on costly, large-scale projects in an era of diminishing budgets.

ScienceLogic: How do you build a sense of community at the Collaboration Project?

Dan Munz: Some community feel emerges naturally, from a sense that mass collaboration really is a tool for “doing government” in a whole new way.

The more formal community building mechanisms we have include our web page, where we share insights, news, case studies, and other content – The virtual space serves as an anchor for people, whether they’re experts or beginners, to learn about what we do.

Finally, we are conducting an ongoing series of in-person meetings, usually featuring a leader who has harnessed collaborative technology in what we think is a truly revolutionary new way.

ScienceLogic: How do you hear about cool new government Web 2.0 projects?

Dan Munz: That’s a key question, because part of our mission is to inspire action by finding leaders who have succeeded and highlight their accomplishments. We’ve done that with folks like Kip Hawley, TSA, Molly O’Neill, EPA, and Jim Walker, Alabama DHS.

We also feel that the Academy’s position as a “safe space” for leaders means that we’re a place people can turn to when they hear about an emerging trend or project and want some help making sense of it.

ScienceLogic: What are the most innovative uses of Web 2.0 technology you’ve seen in the government?

Dan Munz: It’s important to distinguish between agencies that are simply adjusting to the reality of web 2.0, and those that are “using” it. Getting a YouTube account for your agency, or putting some photos on Flickr, is a great first step, but we want to inspire leaders to really transform their normal ways of doing business. At the moment a few that come to mind are the EPA Puget Sound Mashup, ODNI’s Intellipedia, TSA IdeaFactory, the PTO Peer-to-Patent Project, and Virtual Alabama, to name a few.

The TSA launched the IdeaFactory in February 2008. TSA set up a collaboration platform with commenting, voting, etc. to form communities in a way to bring people to consensus and offer ways to improve the agency’s performance.

ScienceLogic: Do you see a difference between state and local versus federal adoption of Web 2.0?

Dan Munz: That’s a hard generalization to make – at all levels you see leaders who recognize the potential in this technology to bring new voices into the governance process.

ScienceLogic: What are the obstacles to Web 2.0 adoption by government agencies?

Dan Munz: The three main challenges that we see are in the areas of technology, culture, and policy/governance.

The technology issue is probably the simplest to solve – it’s important to choose a technology that fits the problem you’re trying to solve, but these technologies are usually inexpensive and almost never very complex.

The question of culture is harder, particularly given the way that baby boomers, gen-xers, and millenials are beginning to interact in the workforce. How do you gain acceptance and buy-in among groups that have very different comfort levels with collaborative tools and environments?

Finally, the most daunting challenge might be the questions of policy and governance, if only because those are the things that most commonly prevent leaders from even dipping a toe in the waters of collaboration. Most of the policies, regulations, and statutes governing the way government does business don’t anticipate things like wikis, blogs, or instant messaging. One of our most important missions is helping leaders who just want to get to action navigate these obstacles.

ScienceLogic: Is there any advice you can give to government employees getting started with Web 2.0? Or any places you would point them to for more info?

Dan Munz: It’s shameless plug time! I’d of course point them to our web page, collaborationproject.org, where, among other things, we’ve collected a case library of over 40 instances of collaborative technology being used in the government and non-profit sectors. The library is growing every day and is a sort of “database of record” for what is and isn’t working in terms of collaborative government. I think that would be a great place to start for anyone looking to get started but not really knowing the way.

In terms of advice, the best thing to say is that, once you’ve settled on a problem you want to solve and an audience you want to reach out to, just do it! We believe strongly that there are a lot of organizational and leadership issues that still need to be addressed regarding collaboration in government, but our biggest mantra is about getting leaders to action. The most successful projects we’ve seen are ones that try something daring and new, and discover the true power of what they’ve done as it catches on more and more widely.

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