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Financial Services Law Insights and Observations

Comptroller Highlights Emerging Cybersecurity Risks, Discusses OCC and Financial Institution Responses

OCC FFIEC Privacy/Cyber Risk & Data Security

Privacy, Cyber Risk & Data Security

On September 18, in remarks before the Exchequer Club, Comptroller of the Currency Thomas Curry highlighted the emerging operational risks for financial institutions posed by cyberattacks, one of several risk areas identified by the OCC in its recent semiannual report. Comptroller Curry bank cyberattacks have lead to only minor disruptions so far, but are evolving and growing with the development and implementation of new technologies. The Comptroller identified the OCC’s and other federal banking agencies’ attempts to address these risks, including through an FFIEC working group created earlier this year. The Comptroller hopes the working group will address cyber issues through changes to examination policy and by supporting increased information sharing and communication between regulated institutions and their regulators, as well as among regulators and other government entities. According to the Comptroller, the OCC currently is engaged in outreach on this issue to all of its regulated institutions, but is especially focused on assisting community banks and thrifts. The Comptroller urged financial institutions, their boards, and senior level management to be aware of and engaged on the risks posed by cyber threats, including, for example, by considering the potential for new products or strategic business decisions to create new vulnerabilities. He also implored institutions and their leaders to effectively share information, such as through industry cyber threat sharing organizations.