Cybersecurity for the Mortgage Industry — Part 2

Poorly designed processes increase cyber risk

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⚙️ Part of my series on Automating Cybersecurity Metrics. The Code.

🔒 Related Stories: Mortgage, Real Estate, Banking, and Legal Security

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Complexity is the worst enemy of security

So said Bruce Schneier, world-renowned security expert, back in 2012. That concept has always rung true to me when I think through how controls need to be applied to achieve testable and provable security. It’s similar to another quote traditionally accredited to Einstein:

Everything should be made as simple as possible, but no simpler.

The more complex things are, the harder they are to manage, the more error-prone they will be, and the easier it is for an attacker to slip into the cracks. At the same time, if you make things too simple like ditching network security and zero trust because it’s hard and just leave your networks wide open, you’ll potentially miss attackers on your network. We need balance simplicity and complexity, but somehow this process I’m going to describe to you swings in the direction of excessively complicated. My real estate agent said it was the worst process she’d seen a customer go through.

Overly complex processes in the banking industry require executive interventions. It’s not the fault of the people carrying out the process.

I come into this experience with some understanding of banking systems and financial processes and what people need to do to support them. I often do cloud pentests for banking systems used by smaller banks and financial institutions. My experience includes building and securing financial systems including e-commerce, tax-related systems for Fortune 500 companies, and building banking back-office systems for Capital One Investing. I also worked on the original Capital One cloud team, helping the first major bank in the United States move to the cloud. I taught cloud security classes to some of the largest banks in the U.S. and Canada when I used to do that. Now I focus on pentesting, assessments and answering questions through IANS Research.

Before I explain the story of trying to get a mortgage with a particular mortgage lender starting in February and ending in May, I want to tell you that I have recently had a very much more pleasant and absolutely positive experience with a local bank. The new bank approved a loan in a few days. The first time. The second time I was sent to another department and more weird things happened. The inconsistency is troubling.

I find that it will likely be easier to deal with a small, local bank when it comes to getting a loan if you are in the non-standard category of borrowers, as I am (small business owners). I mistakenly thought I was using a local bank when I started the process described below. Only in the end did I realize that I was dealing with a behemoth when the last very nice person I talked to was in California.

Everyone in the process was very nice, but I presume constrained by external factors outside of their control.

I recently moved to Savannah mistook the bank I selected for a local one because someone here recommended it, and it was in a particular category of banking like one I used in Seattle which was also local. People I talked to had sweet Southern drawls and exuded hospitality — something that I love here.

Everyone was so helpful during the process until the very end when it all fell apart and I just couldn’t understand how it could be so exasperating and what happened to the pleasant people who were previously helping me. They disappeared and wouldn’t respond to me, the law firm, or my real estate agent. A person at the law firm I was dealing with tells me this is not a unique experience when it comes to dealing with this particular financial institution. They drag out everything until the end, create repeated delays, and don’t respond to questions.

I don’t understand how organizations can remain in business this way, but they serve a particular government body so perhaps that has something to do with it. Maybe people who fall into their standard category don’t have so many issues because they fall neatly into the proper criteria typically used to approve loans, but I still find it incredulous how this process played out.

Cybersecurity problems resulting from an overly complex process

The length of time this process drags on is a security risk, as are the seemingly endless rounds of paperwork. As more and more paperwork gets shuffled around— some of the same documents multiple times — there is more chance that something goes to the wrong place or gets in the wrong hands. The more time paperwork is flowing back and forth, the greater the chance for a leak during the process.

The more paperwork the bank holds, the more risk and exposure in the case of a data breach. Some fines for data breaches are based on the number of records exposed. Perhaps you need those bank statements for two months. But the repeated requests for months and months of statements as the process goes in circles between the people who were helping me, the supervisors, and the underwriters?

As the unfortunate people at the bank I was interfacing with have to go back and forth between me, their supervisors, and the underwriters, I can only imagine their job is very stressful. When people are stressed, they make mistakes. Reports such as the Verizon Data Breach Investigations Report in 2021 indicate repeatedly that humans are most often one of the culprits in data breaches. More on that topic as it relates to the horribly broken and fragmented systems people are using that lead them to make less than ideal cybersecurity decisions in the interest of helping people and getting their jobs done. But a dysfunctional process doesn’t help either.

Ill-defined processes lend themselves to gaps where attackers can slip in and take advantage. I’ll talk about how attackers can slip into wiring processes later. When it comes to providing paperwork for a loan, the process seems somewhat arbitrary and inconsistent. People gathering paperwork from customers do their best to navigate the uncertainty. Paperwork may be submitted in different ways and end up going through many hands.

When it comes to getting paperwork and information quickly, people who are not well-trained in security may make judgment calls that increase cyber risk for an organization. Along the way, people made mistakes trying to be helpful. I went to the branch to submit documents due to a broken document system and to ensure my documents were not sent via email. At one point someone confirmed receipt of a document…by sending it back to me in email. I do not blame the woman who sent me this document. I should have not had to go to the branch in the first place and then that never would have happened.

While working with another lender recently, their process required me to give them sensitive data over the phone. Really? Why can’t I enter that data into a secure portal? The person on the phone (again very nice) said they are one of the largest mortgage lenders in the United States. I started the process but opted not to go with that company. Sometimes the only way to get information from a bank on the phone is by giving out sensitive information, so this was another reason I opted for a local bank.

I’ve noticed other companies asking for this information as well. It’s a pain when you can’t remember your account number, but an alternative approach would be to have the person enter a number on the phone keypad to look up the account before they get to an agent for existing accounts. For new accounts, use a secure portal to capture the information.

I wrote about the need for training that focuses on fundamentals and how to think about cybersecurity rather than focusing on the technical details alone. People don’t need to be technical experts to be better at security. But not everyone on the team will have time to attend cybersecurity classes or remember everything you teach them as their brain is generally focused on their primary job, so set up processes where they are not put into the position of making risky decisions.

Separate the people from the data in the process to disallow people from accidentally exposing data. Focus on streamlining processes to eliminate unnecessary and duplicated steps and paperwork. Focus on minimum time and data to get it done to prevent mistakes. Make sure your systems work! Stay tuned for some of the problems I experienced in all sorts of platforms involved in this process in future blog posts.

Consider the process for exceptions carefully, such as the case of small business owners that do not fall neatly into the standard categories where a paycheck stub satisfies the requirements. The exceptions are often a place where security problems exist and problems tend to sneak into your processes.

Although I’m going to tell you the process of one specific case, and undoubtedly an exceptional one based on the comments from my real estate agent and law firm, I’ve dealt with similarly frustrating processes in the past. Several cybersecurity professionals made comments on this topic with their own related experiences in a recent LinkedIn post. The way many mortgage lenders capture documents to approve loans could use some serious streamlining, which in turn would help improve cybersecurity at the same time. This is before we even talk about the technical issues. I suspect that companies that can make this process easier would also get more business.

The grueling paperwork process for small business owners

The whole criteria to obtain a home loan as a business owner seems completely illogical to me most of the time. I could write a whole blog post on this topic alone. During the pandemic, my business was impacted by my inability to travel and teach and speak at conferences around the world. Although my gross receipts went down, my expenses went down dramatically as well due to lower travel expenses. I intentionally cut back to reduce business expenses due to the uncertainty of the environment. In the end, my net income was not too badly impacted, and I didn’t feel that I needed more net income. My company was able to survive and pay all bills on time.

The bank saw it differently. Just because my gross income dropped by over a certain percentage some banks would not even consider my loan. They disregarded the fact I just sold a house for a significant profit and was buying a cheaper one. They disregarded excellent credit and never being late on a mortgage payment for over 8 years at my prior residence or the fact that I had no other home, car, or student loans. I pay off my credit cards every month. They did not consider that my net income was still easily enough to cover the loan or that I had years of mortgage payments in the bank even after paying a substantial downpayment.

I asked one mortgage company, “So if my income went down from $1 million to $500,000 you would flat out reject me with your formula?” Yes, apparently. I was not at that level of income but you get the idea.

The banks that outright rejected me were frustrating but at least they weren’t introducing cybersecurity risks into their processes. They had clear-cut processes and although their employees apologized profusely for the illogical nature of the decision, it was over and done quickly. I appreciated that, at least. Thank you for not wasting my time or yours if you will ultimately reject the loan due to your particular formula.

Unfortunately, another mortgage lender dragged me through a long and painful process. The egregious amount of time dealing with the bank combined with a contractor in Seattle that repeatedly delayed a project to the point it negatively impacted by business income caused me an inordinate amount of stress. I couldn’t get on with my move, my life, and my business as a result of all these issues.

As you read my story below, consider what the organization could have done to simplify this process and reduce the points of potential data exposure. What could be done to reduce the amount of paperwork and people involved and prevent mistakes? Check out my recommendations at the end of this article for how I think the process could be improved.

A convoluted process:

• In December and January, I took some time off from my business and worked on my house and packed up belongings getting ready to sell. I was cleaning, painting, fixing doorknobs, installing lights, etc. I also hired some contractors to finish some projects and was managing them as well. The time spent on my house impacted my business income so I was a bit concerned about it, but was planning to get back to my business shortly after selling the house which my agent and I suspected would be about the first week in February.
• One of the contractors was supposed to finish a project in January per written communication, worst case the first week of February.
• Based on the expected timing, I applied for the loans in late January and early February to buy a new home.
• Typically the lending process involved submitting an application and then the bank comes back once they know you are a business owner and asks for numerous other documents: P & L, balance sheet, copy of two years of taxes, business formation documents, operating agreement or similar, copies of personal and business bank statements, business questionnaire, and in some cases, form 4506-T to get my tax transcripts from the IRS.

WHY if you know you are going to ask for all these documents when a person is a business owner can you not ask for it all at the point you accept the application? This is a complete waste of everyone’s time, and as you see below, some banks come back, again and again, asking for more paperwork. You should know what paperwork you need to make these decisions for different scenarios into online systems and handle these requests efficiently and securely! Also, if you require a certain level of net income or two years of business tax returns, tell people that BEFORE they waste time submitting an application and storing more sensitive documents that are not going anywhere because you know you are going to reject them even before you get those documents.

• I flew to Savannah at the end of January thinking the contractor I hired would complete their project shortly. They didn’t. They kept promising a date and missing it.
• Due to the uncertainty of when I could put the home on the market, I could not even put an offer on a house because people don’t like that contingency without a firm date. I couldn’t figure out when I should fly back to inspect their work and when I could close in Seattle due to their inability to commit to a completion date. I didn’t have a place where I could do all of my work in Savannah. Should I rent office space or just wait?
• My business was a bit in limbo while they delayed a project multiple times from January until March. In fact, the work didn’t match my specifications in March but I couldn’t wait any longer to fix it. I needed to get my house on the market so I could put offers on houses.
• Meanwhile, after having several mortgage lenders outright reject me for what seemed like illogical reasons, including the one that approved my previous refinance, one of the banks I was working with told me I was approved and gave me paperwork to prove it.
• I used the approval to make an offer on a house shortly before I sold my home in Seattle in March.
• I was still nervous about my income due to the issues with the Seattle contractor delays impacting my ability to schedule work, so I asked the bank for confirmation that my loan was approved.
• The bank reassured me my income was verified and assured me there was no problem with my loan. They just needed to get my tax transcripts from the IRS. I had already provided copies of my taxes. I made one mistake on the initial 4506-T form and forgot to check a box. When they told me this I fixed and returned it the same day. It seemed to take a long time for them to tell me this but there was still plenty of time to request the transcripts. Supposedly that was all they needed.
• I sold my house in Seattle for a decent profit and moved over the amount of the 20% down into the bank I was working with that had supposedly approved me and told other lenders I would not be using them as they were taking even longer to make a decision and I needed to get back to my business obligations.
• Then I waited. The bank was not getting back to me and the closing date was approaching. I didn’t want to harass them but I contacted them once again to find out if everything was OK and when I would get the final paperwork.
• Finally, I got a response — it was two weeks until closing and the bank still could not get the tax transcripts. At the beginning of the process, a woman at the bank had told me that it takes two weeks to get the transcripts. It had been much longer than two weeks since I submitted the corrected tax transcript request form. Another woman was contacting me she just found out there was a problem and blamed her systems. Now we were running out of time! The process started in February and they were just now trying to get this fixed in mid-April?!
• To correct the problem, she told me to put a different address on the second line of my tax transcripts, but the instructions on the 4506-T form clearly say to use the address that is on your taxes and that was not it.
• I remembered when checking on covid related issues at the IRS website that the site failed with an error. By chance doing some research, I stumbled across an article that a number sign (#) in the address caused queries to fail and that fixed the problem. My mailing address includes such a symbol. However, it appears that when you submit your taxes through an online system it strips out that number sign, but I didn’t notice. After scrutinizing my returns to see what might be different with my address, I ended up removing the symbol in my address on an updated 4506-T form and sent it back to them. I hoped that was the issue but it wasn’t clear that was going to resolve the problem.
• Somewhere along the way, having the money for the down payment in their bank wasn’t enough. The bank wanted proof that I received the funds from a real estate transaction. They wanted a new bank statement but I could only send a screenshot since the transaction had just occurred so was not on a statement. The woman helping me said she would make sure that was OK but never got back to me.
• I also had to provide documentation related to the real estate sale, which I did. I was again told everything was ok except the tax transcripts.
• At this point, it was very late in the process and the woman said they could likely waive the tax transcripts. She said they would send me an agreement for the loan. When I got it, it still showed escrow for taxes and insurance which I had asked them to remove.
• They had agreed to request removing the tax and insurance in escrow and I was told based on my credit and past mortgage history that should not be a problem. The woman told me not to sign it and it would only take a couple of hours for her to get me a new copy without the escrow.
• The updated form never came. Three days passed. The form expired that I was not even able to sign for the supposedly approved loan that included escrow.
• No one was responding to questions.
• At this point, my real estate agent was alarmed because a real estate transaction with a mortgage requires a three-day waiting period. I didn’t realize this and scrambled to reach the bank to find out what was going on and no one would respond. Where was my agreement that was supposed to come “in a couple of hours?”
• I had contacted the law firm handling closing and we had the ability to do an 8-day extension after closing, so I felt slightly and mistakenly relieved.
• I couldn’t get anyone to respond from the bank but my agent got ahold of someone who said they were still waiting on tax transcripts.
• This was frustrating because another woman told me they would waive those transcripts. I got online and sent a message asking about being told those could be waived. The bank had two different people contacting me and apparently they were not communicating or giving consistent messages.
• Finally, they responded the day before I needed to wire money for closing(?!) and told me that they would accept tax transcripts if I could download them from the IRS website myself.
• This wasn’t in time for closing so my agent and attorney moved closing to Monday.
• I had previously logged into the IRS website so I thought that would not be a problem but when I tried to log in I got errors. Unfortunately, the website failed to allow me to log in or create an account. Then I got a message saying they would mail me a code in 8 days that I could use to create my account. That was too late!
• At this point, I called the IRS and sat on hold for about a day trying to reach different departments to fix the problem and figure out what to do. I finally reached a woman who couldn’t really help me but she looked at my address and said there was something wrong with my address and fixed it. I have no idea what she did or if it is fixed. The bank never got the transcripts as far as I know.
• I reached out repeatedly to the bank to see if there was anything else I can do. No one said “No, this is your only option.” They simply didn’t respond at all! I kept them informed of what I was trying to do to get the transcripts and they completely ignored the messages.
• Besides sitting on hold and pushing many different combinations of buttons on the IRS phone line to try to reach a person (try #1, #2, #3), I also researched all over the web and figured out that I might be able to make an appointment at an IRS office to get the tax transcripts in person.
• I found an IRS office address in Savannah and tried to make an appointment. I was on hold again and got through to a woman who seemed very cranky and was trying very hard not to give me an appointment because she said I could get the paperwork online. I would just have to wait. I explained my scenario and literally begged her for an appointment and she eventually obliged.
• Now for finding an appointment. There were none available at the Savannah office for over a month, nor were there any at other nearby offices. Finally, she found an office in South Carolina with appointments available the next day.
• I drove to South Carolina that night, paid for a hotel, and got up first thing in the morning to get the tax transcripts. They were very nice at the IRS office and understanding of my situation. The bank never responded to any messages while I explained what I was doing and asked if this was the only alternative so I just kept proceeding.
• I felt a little silly going through the IRS security check-in with two laptops and an iPad but I explained to the security guards that I work with computers and they didn’t ask much. Mind you, I’m trying to get work done during this whole fiasco. I had multiple proposals that were very much delayed while I was trying to deal with the bank and probably lost some business in the process, but I was also working on some contracts.
• Luckily the bank had a branch in the same town as the IRS office. After getting the transcripts, I went straight to the branch. I waited in an extremely long line to get into the branch. I sent a message to the people I was working with to let them know hoping they would get someone out there to help me cut the line, but no. I was probably there over an hour. The woman at the branch was very helpful once I got into the branch and quickly sent my paperwork to the women helping me and they confirmed receipt to her.
• So now it’s the day I need to wire the money for closing and the bank has my tax transcripts and they still aren’t responding.
• After 5 p.m. the day I submitted the tax transcripts in the morning, I get an email from the person who has been helping me with paperwork. She says she tried to call me but my phone cut off. I have no record of these calls. She also has my real estate agent and the law firm’s email and phone number and she did not call or text them to tell me to call her.
• Besides, that wouldn’t help. Her voicemail is always full and she never answers. One time while talking to me she said she had a family emergency and came back to over 600 messages. I have a feeling this woman is overwhelmed. When people have more messages than they can keep up with due to so many problems in a process, what do you expect them to do? This problem requires a change at the executive level, as stated before. The process is not efficient, effective, or facilitating the desired outcome and is going to be prone to security problems as a result.
• Her email says that they need more paperwork and includes a list of about 6–8 new forms of documentation they will require for the loan. As a reminder, it’s after 5 p.m. the day before closing! Also as a reminder: there is a three-day waiting period to obtain a loan so there’s no way I’m going to close in time, and the next day is a Friday so I’m running out of time for the closing extension as well.
• They had already requested a screenshot of the deposit for my home sale in Seattle. They had already requested my home sale document from Seattle. They had also later requested a copy of the bank statement showing the home loan deposit after the statement appeared.
• Now they were re-requesting my P&L, bank statements for different periods including business statements, and re-asking the questions I answered on the business questionnaire. They want me to sign my tax returns submitted electronically and my P & L. I wasn’t sure what to do so I signed them and initialed all pages. They wanted proof that I had registered my business in Georgia so I sent that. They also re-requested real estate documentation for my home sale in Seattle. When I asked them what they needed since I already sent that they did not respond, so I sent them every piece of paper I had related to that sale. I think I sent proof of my leased office space for my business location. I understand they might require this documentation but first of all, I already submitted it, and also now it is TOO LATE FOR CLOSING! And it is approaching the deadline for the 8-day extension as well.
• So I submit all the paperwork immediately (another trip to the branch due to broken systems) and include two contracts showing plenty of income. And I wait. But I start to think about how incredibly ridiculous this process is and that something is seriously wrong with this lender. A feeling comes over me that I don’t want anything to do with this bank if I can avoid it.
• I wonder if I can just pay for the house another way and begin making other arrangements. I contact the lawyer handling the mortgage and ask how much money I need to come up with and start thinking about how else I can get this done and make some calls.
• Before I take additional steps to get the deal done another way, I call the bank and beg (yes beg) the very nice customer service person to keep me on hold until she can get me a live person to speak to so I can get the status of the loan. She keeps coming back telling me no one in that department will answer. I beg her to keep trying. She is kind enough to do so.
• The person I have been dealing with in regards to paperwork isn’t answering. She has always been super nice up to this point. The other person went on vacation without telling anyone. Her supervisor I’ve never spoken to won’t answer. None of the other supervisors will answer. I haven’t spoken to anyone at this bank for over a week, maybe two, and only received maybe two or three emails throughout all of this. Finally, she gets the supervisors’ supervisor. That person gets a supervisor (not the supervisor of the person I was working with) to come on the phone and talk to me.
• I explain as nicely as possible that I need to know immediately what is going on with this loan as my contract is expiring and I may need to make other plans. She goes off and gathers some information and tells me that my loan was rejected. Yesterday. No one bothered to tell me.
• She was understanding and very nice. At this point, I’m done with this lender, but I explain the entire scenario anyway to help her understand the impact it had on my business and my life. I got sick during this time period and couldn’t get over it. I went to a doctor, and then a specialist who suggested it was stress-induced. I was completely stressed by the bank and the Seattle contractor. I’m better now so I think he was right.
• The supervisor in California promised to pay for my hotel in South Carolina. I sent the woman who was helping me with paperwork who is located in Alabama, I think, a receipt. I haven’t seen that payment. Maybe the check is in the mail. (Update: It wasn’t. I never got it.)
• The supervisor says she’s going to go back and talk to underwriting and I say OK, but it was too late. I immediately got off the phone and officially started the process to get the house another way.
• I’m so grateful to the seller and agents for working with me on this so we could complete this sale with yet another delay.
• The bank tried to call me back at about 5 p.m. ET that night but it was too late. I was done with them. I didn’t feel like answering. I figured they would understand given how hard it was to reach anyone on the phone over there. I took my money out of their bank and closed my account the following week.

Too many documents, too many times, and lack of effective results!

Not only was this process completely infuriating, stressful, and a huge waste of time, it was fraught with security problems. I’ll go into detail on some of those in upcoming blog posts concerning some technology problems I experienced with this company and others. But all this paperwork flowing around unnecessarily through many different hands at branches and all this back and forth is part of a process that is just asking for security problems.

How many different people at different branches dealt with my paperwork? How many email accounts have my documents in them because technical portals weren’t working and the documents were requested incrementally over months? How many people in underwriting looked at my documents, I wonder? And the supervisors? Branch employees. How does the amount of frustration and number of documents going back and forth impact people’s decisions to just send the documents in email to get it done quickly?

This is not a new issue. I’ve dealt with and decided not to do business with mortgage lenders in the past where the person talking to me and trying to get all the paperwork to the underwriters couldn’t get information in a timely manner as to what was required or did not provide accurate information. It seems to be a problem in the industry between the people gathering the paperwork and the ability for underwriters to respond accurately, consistently, and promptly.

The other problem is that the banks don’t provide exactly what paperwork they need upfront before it goes to the underwriters. This is not rocket science. I’ve been through this process as a business owner at multiple banks and they all ask for roughly the same information. By the time I got to the last bank, I had a well-organized stack of paperwork and included some documents they did not request as well because I knew they would ask for them later.

Failure to identify a problem with the paperwork in a timely manner. Delays in the process require additional and repeated versions of paperwork. The last-minute rush is certainly a point at which things go wrong. People are in a hurry to get a document to someone and finally just give up and send it in email or provide documentation in some other insecure manner.

Solution: Streamline the process

As I already mentioned, without even considering the technical pieces yet, the solution for this particular aspect of the mortgage lending process would be to streamline the process.

• Reduce the time it takes to complete the process and data is accessible.
• Remove unnecessary steps.
• Make the process consistent.
• Avoid duplication.
• Minimize the number of people who have access to documents.
• Figure out what documentation different scenarios require.
• Ask for all documentation upfront, one time.
• Collect the minimum documents required. ONE TIME.
• Alert customers to potential document errors upfront.
• Identify documentation errors and resolve them early.
• Streamline communication processes.
• Provide a path for escalation (which will be reduced if you streamline your process!)
• Provide a mechanism for employee feedback on the process.
• Time how long each step of the process takes. Fix the longest step first.
• Categorize different types of applications and related errors. Fix them.
• Make sure your file upload portals actually work.
• Do not request sensitive data over the phone.
• Do not have customer service ask for codes of any kind.
• Do not direct customers to click links sent from customer service.
• Have customers log into a secure portal to access information.
• Tell every employee not to use email to send documents, even internally.
• Archive data securely once the process is complete.

As I’ll explain in upcoming posts you can leverage automation and secure systems — that work — to avoid some of these and other security issues I faced throughout the process.

Follow for updates.

Teri Radichel | © 2nd Sight Lab 2021

About Teri Radichel:
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⭐️ Author: Cybersecurity Books
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⭐️ Certifications: SANS ~ GSE 240
⭐️ Education: BA Business, Master of Software Engineering, Master of Infosec
⭐️ Company: Penetration Tests, Assessments, Phone Consulting ~ 2nd Sight Lab

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