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Financial Services Law Insights and Observations

CSBS Publishes Annual Report

Examination Privacy/Cyber Risk & Data Security

Privacy, Cyber Risk & Data Security

Recently, the Conference of State Bank Supervisors (CSBS) published its 2015 Annual Report to provide an overview of its activities and initiatives in 2015. The report highlights that, throughout 2015, state regulators (i) increased coordination and collaboration between state regulators and other stakeholders, including federal regulators and Congress; (ii) developed research and analytical tools, such as risk profiling tools to assist with the examination selection process, as well as tools to address emerging non-depository regulatory issues; (iii) developed “right-sized” policy solutions for an ever-changing financial services industry, acknowledging that “community banks play a vital and necessary role in [the] diverse financial services ecosystem”; and (iv) provided education and training for examiners and supervisors, noting that “more than 1,000 examiners from 43 agencies representing 41 states had been certified through the CSBS Certification Program.” Importantly, the report notes that cybersecurity remains a “major issue facing the financial services industry.” In an effort to encourage executive leadership and raise awareness, CSBS launched the Executive Leadership of Cybersecurity (ELOC) initiative, which emphasizes that cybersecurity is “more than a ‘back office’ issue, but an executive issue that requires CEO and Board level attention.”