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Jim Freis Comments on Computer-Security Incident Notification Requirements for Banking Organizations and Their Bank Service Providers

Jim Freis submits comments on the proposed Fed, OCC, FDIC regulations dealing with bank and third party service provider responsibilities managing business disruptions and cybersecurity events.

CRINDATA™ Chairman and Chief Strategy Officer Jim Freis submitted comments on the Computer-Security Incident Notification Requirements for Banking Organizations and Their Bank Service Providers: https://www.federalregister.gov/documents/2021/01/12/2020-28498/computer-security-incident-notification-requirements-for-banking-organizations-and-their-bank

The comments appear here: https://www.regulations.gov/comment/OCC-2020-0038-0017 and are republished on the CRINDATA Blog: https://crindata.com/blog/category/blog/.

The proposed regulations require that all banking organizations give prompt notice to their functional regulator of qualifying business disruptions and cybersecurity events.  They also require vendors/third party service providers to give “immediate” notice of certain business disruptions and cybersecurity events to their bank customers.

“Regulators across the globe, especially in the EU and the US, are requiring financial institutions to quantify and mitigate the risks of outsourcing critical services to third parties,” said Freis, Chairman and Chief Strategy Officer of CRINDATA.  “Regulators recognize that critical outsourcing is here to stay, and the banks should map and understand how third party business disruptions and cybersecurity events could adversely affect the banks’ business and customers,” said Freis.

About Jim Freis:

Jim has devoted his career to promoting the integrity of the global financial markets.  He is best known in the United States as the longest-serving Director (2007 to 2012) of the United States Treasury Department’s Financial Crimes Enforcement Network (FinCEN), overseeing regulations covering the broadest range of financial institutions in coordination with their primary licensing authorities, and for applying data-driven efforts to combat fraud exposed through the Global Financial Crisis. After FinCEN, Jim was based in Frankfurt, Germany with the Deutsche Börse Group, Europe’s largest provider of systemically significant financial market infrastructures, responsible for overseeing compliance and relations with global regulators including in the implementation of a holistic internal control system approach among Risk, Compliance, Information Security and Outsourcing oversight functions.  

About CRINDATA:

CRINDATA, LLC (www.CRINDATA.com) offers unique cloud-based solutions to financial institutions who must actively manage their critical third-party relationships (including their indirect relationships with subcontractors) and must prepare for and mitigate business disruptions management and cybersecurity events originating anywhere in the chain of service providers and subcontractors. Concurrently, CRINDATA helps third party service providers like core systems, payments providers, transaction motoring solutions, banker’s banks, and corporate credit unions, by substantially simplifying the due diligence interactions with financial service companies and by providing a complaint, common platform to manage business disruptions and cybersecurity events when they occur. 

Reach CRINDATA at info@crindata.com

202.990.6990

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