On October 19, 2016, the Federal Deposit Insurance Corporation, the Federal Reserve Board and the OCC (collectively, the Agencies) released an Advanced Notice of Proposed Rulemaking (ANPR) laying out a framework for enhanced cyber risk management standards that the Agencies are considering requiring of certain “large and interconnected” financial institutions. The Agencies have not yet proposed specific standards in a formal proposed rule. Instead, the Agencies have laid out a framework that they are considering and have requested comment on a series of questions that will inform a later, more specific proposal.
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