Written Information Security Program

Last updated: May 11, 2026

1. Purpose and Scope

This Written Information Security Program ("WISP") documents the administrative, technical, and physical safeguards RAVEN maintains to protect the confidentiality, integrity, and availability of customer information processed through the platform. It is designed to satisfy the Gramm-Leach-Bliley Act Safeguards Rule (16 CFR Part 314), the FFIEC Information Security Handbook, and the data-protection elements of the CFPB Personal Financial Data Rights Rule (12 CFR Part 1033).

This WISP applies to all RAVEN employees, contractors, infrastructure, third-party service providers, and to all consumer data processed on behalf of RAVEN's customers (U.S.-chartered, federally insured depository institutions).

2. Qualified Individual

The Qualified Individual responsible for overseeing, implementing, and enforcing this WISP is the RAVEN Security Lead. The Qualified Individual reports to the governing body at least annually on the status of the program, material risks, results of testing, and any security incidents.

3. Risk Assessment (16 CFR §314.4(b))

RAVEN conducts a documented risk assessment at least annually and whenever there is a material change to the platform, the threat landscape, or the regulatory environment. The risk assessment:

4. Safeguards (16 CFR §314.4(c))

4.1 Access Controls

4.2 Asset and Data Inventory

4.3 Encryption

4.4 Secure Software Development

4.5 Multi-Factor Authentication

MFA is required for all access to administrative consoles, source control, the identity provider, and any system that can decrypt customer information. The requirement applies to RAVEN staff and to any third-party support engineer granted temporary access.

4.6 Monitoring and Logging

4.7 Secure Disposal

Customer information is retained only as long as necessary for the consumer-requested product and applicable legal retention. Disposal is performed by crypto-shredding (DEK deletion), which renders the underlying data permanently unrecoverable. Disposal events are logged.

4.8 Change Management

All changes to production systems flow through source control with peer review. Schema changes, key-management changes, and changes affecting the audit trail receive additional review by the Qualified Individual.

4.9 Incident Response

RAVEN maintains a written Incident Response Plan (published at /legal/incident-response) that defines roles, severity tiers, escalation paths, evidence preservation, and notification commitments.

5. Service Provider Oversight (16 CFR §314.4(f))

RAVEN's Vendor Risk Management Program (/legal/vendor-risk-management) governs the selection, contracting, and ongoing oversight of all third-party service providers that receive or process customer information. The current list of subprocessors is published at /legal/subprocessors and updated with notice to customers on material change.

6. Testing and Monitoring (16 CFR §314.4(d))

7. Training (16 CFR §314.4(e))

All RAVEN staff complete security awareness training at hire and annually thereafter. Engineering staff complete additional secure-coding training. The Qualified Individual maintains training and credentials sufficient to the role and tracks the program's training compliance.

8. Customer and Consumer Information

RAVEN classifies customer information broadly to include nonpublic personal information received from financial institution customers and from consumers (including SSN, date of birth, account information, transaction history, and any other data processed through the platform).

9. Annual Review and Reporting (16 CFR §314.4(i))

The Qualified Individual reports to the governing body in writing at least annually. The report covers:

10. Contact