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Fed Reports on Cybersecurity and Financial System Resilience

By Moorari Shah, A.J. Dhaliwal & Snehal Desai on August 5, 2022
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Recently, the Federal Reserve Board (Fed) published its annual Cybersecurity and Financial System Resilience report describing measures it has taken to strengthen cybersecurity in the financial services sector, including the supervision and regulation of financial institutions and third-party service providers.

The report highlights an increase in the number of cyber threats. Ransomware, in particular, has been rampant, and the effects of ransomware attacks could be particularly deleterious to smaller banking organizations. Increasing geopolitical events, such as Russia’s invasion of Ukraine, have also lead to the potential for increase in cyberattacks in the U.S., which could affect financial systems. Finally, the Fed acknowledges that a cyberattack of a vendor or third party could impact banks due to supply chain compromise.

Putting It Into Practice: The Report highlights the importance that the Fed has placed on cyber-risk mitigation and cyber resilience initiatives and is a good reminder for financial institutions that as the risks increase, they should prioritize their cyber security protocols and should use the Fed’s guidelines to mitigate risk. This latest report is consistent previous rulemaking from the Fed, OCC, and FDIC to improve information sharing about cyber incidents that may affect the U.S. banking system that, among other things, requires banking organizations to inform their primary federal regulator no later than 36 hours after a determination that a “computer-security incident” has reached the level of a “notification incident” (we discussed this rulemaking in previous blog posts here and here).

Photo of Moorari Shah Moorari Shah

Moorari Shah is a partner in the Finance and Bankruptcy Practice Group in the firm’s Los Angeles and San Francisco offices.

Read more about Moorari ShahEmail
Photo of A.J. Dhaliwal A.J. Dhaliwal

A.J. is a partner in the Finance and Bankruptcy Practice Group in the firm’s Washington, D.C. office.

Read more about A.J. DhaliwalEmail
Photo of Snehal Desai Snehal Desai

Snehal Desai is an associate in the Intellectual Property Practice Group in the firm’s San Francisco office. She is a member of the Privacy and Cybersecurity Team, the Advertising Team and the Technology Transactions Team.

Read more about Snehal DesaiEmail
  • Posted in:
    Banking, Finance and Securities, Privacy and Cybersecurity
  • Blog:
    Consumer Finance and Fintech Blog
  • Organization:
    Sheppard, Mullin, Richter & Hampton LLP
  • Article: View Original Source

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