On December 6, 2021, the National Risk Committee of the Office of the Comptroller of the Currency (OCC) issued its Semiannual Risk Perspective for Fall 2021, which reports on key issues affecting the federal banking system.[1] The report highlights the “evolving and increasingly complex” danger to the financial system from cyber threats, and encourages banks and financial institutions to adopt robust cyber controls to minimize operational risk. It also stresses the need for risk-management policies and procedures that are tailored to new technological innovations, including cryptocurrencies and other digital assets.
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Banking Regulators Approve Final Rule Establishing Cyber Incident Notification Requirements
On November 18, 2021, the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), and the Board of Governors of the Federal Reserve System (Board) announced a final rule requiring banking organizations to notify their primary regulator of certain significant computer-security incidents as soon as possible and no later than 36 hours after they occur.[1] The rule separately requires bank service providers to notify their bank customers if they experience a cyber incident that causes, or is reasonably likely to cause, a material disruption of services that lasts for four or more hours.
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