Hi Linda,

Short term solution is to implement the RACF password change exit ICHPWX01 and 
its companion System REXX module IRRPWREX module. Relatively simple to 
implement and governs all password changes. IRRPWREX has numerous options you 
can activate, such as disallowing repeating characters and specific character 
strings, that can address the common password prohibition requirement. The 
IBM-provided exit code is available on GitHub:

https://github.com/IBM/IBM-Z-zOS/tree/main/zOS-RACF/Downloads/RexxPwExit

Also, implement KDFAES password encryption if you have not already done so. And 
I recommend a single SETROPTS PASSWORD RULE of LENGTH(8) MIXEDALL(1:8), which 
requires a password to be 8 characters in length and have at least one letter, 
one number, and one special character (e.g., National Characters). This rule 
alone will block many of the common passwords. Be sure all your resource 
managers processing logons can handle special characters.

Longer term solution is MFA.

I recommend you contact the authors of this regulation and ask them to provide 
you with the list of common passwords they expect you to disallow.

Regards, Bob

Robert S. Hansel                       2024 IBM Champion
Lead RACF Specialist
RSH Consulting, Inc.
617-969-8211
www.linkedin.com/in/roberthansel
www.rshconsulting.com

-----Original Message-----
Date:    Thu, 29 Feb 2024 14:53:36 -0600
From:    Linda Hagedorn <linda.haged...@gmail.com>
Subject: Re: RACF, external password management

The regulations are from NY state, NYDFS.  
https://www.dfs.ny.gov/system/files/documents/2023/12/rf23_nycrr_part_500_amend02_20231101.pdf

     500.7 Access privileges and management.

     500.7(c) Each class A company shall monitor privileged access activity and 
shall implement:
     (1) a privileged access management solution; and
     (2) an automated method of blocking commonly used passwords for all 
accounts on
     information systems owned or controlled by the class A company and 
wherever feasible
     for all other accounts.  

To automatically block commonly used passwords, a corpus is necessary.  For 
example, Cybernews Investigation team was able to collect 15m passwords.*  If 
they can do it, software vendors will see the opportunity here.   

It's one option to force all RACF password changes through a single point.  
However, there's a lot of ways to reach the password change process in MVS, and 
writing blocks for all of them isn't reasonable.  
 
The ZMFA holds promise, if I can find a software company that has 
bought/collected the same 15m passwords that Cybernews did.  I can route all 
RACF password changes to the <currently unidentified> software company for 
validation.  


*https://cybernews.com/best-password-managers/most-common-passwords/

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