You signed the
certification.
Can you defend it?
Every April, your name goes on a DFS certification that constitutes a personal legal representation. Your IT provider said the systems are fine. Your compliance officer confirmed the filings are current. What neither of them told you: when the examiner arrives, they don't ask about systems or filings. They ask for evidence.
Your firm has two people
who should own this.
Neither of them does.
Your IT provider manages your systems. Your compliance officer manages your filings. Both are doing exactly the job they were hired to do.
But there is a layer between those two jobs that neither of them was built to own — the governance documentation that a DFS examiner will ask for by name when they arrive at your firm. The penetration test report. The vendor risk assessments. The tested incident response plan. The written information security program, tied to your actual controls, updated and maintained year-round.
That layer belongs to no one in your organization right now.
And your name is on the document that says it does.
The NY DFS annual certification is not a formality. It is a personal legal representation. If an examiner finds a gap in the documentation you attested to, the liability is yours — not your IT provider's, not your compliance officer's. Yours.
Three steps to signing knowing —
not hoping.
The only person in this market who has signed what you sign.
Howard Globus entered financial services in 1994 at First Boston. He served as CIO and functionally as CISO at Allianz Risk Transfer — $2 billion under management.
He has managed DFS examinations from inside the firm. He has carried the personal liability that comes with being the named executive responsible for a governance program under active regulatory scrutiny.
He is not a vendor explaining your situation from the outside. He has been exactly where you are standing.
"Most firms in this market have an IT provider for their systems and a compliance officer for their filings. What almost none of them have is anyone responsible for the space in between."
— Howard Globus, Security Evangelist & Owner, IT On Demand
The Signed & Defended Program.
Built for the executive whose name is on the document.
| Program Component | Standalone Value |
|---|---|
| Core Program: Signed & Defended (CLM) | $26,148/yr |
| Governance Gap Baseline Report | $3,500 |
| Pre-Certification Sign-Off (annual) | $5,000/yr |
| MSP Interface Protocol | $2,400/yr |
| Peer Enforcement Intelligence Briefing | $1,164/yr |
| Examination Day Protocol | $7,500 |
| 90-Day Defensibility Guarantee | Risk elimination |
| Total Stacked Value | $45,712/year |
| Your Investment | $2,179/month |
Objections we've heard.
Answered honestly.
Before you sign again —
find out if your program
is defensible.
The Certification Exposure Assessment takes 30 minutes. You answer 10 questions. We score your exposure. You leave with an honest picture of where your governance program stands.
No pitch. No obligation. No vendor theater.