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- Cyber Incident Notification Requirements for Banking Organizations and Service Providers – Proposed Rule
Cyber Incident Notification Requirements for Banking Organizations and Service Providers – Proposed Rule
December 18, 2020, Covington Alert
On December 18, 2020, the Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, and Federal Deposit Insurance Corporation issued a notice of proposed rulemaking requiring a banking organization to notify its primary federal regulator within 36 hours of a significant cybersecurity incident and requiring a bank service provider to notify at least two individuals at an affected banking organization customer of a significant cybersecurity incident that could disrupt services for four or more hours. The proposed rule’s notification requirement is intended to provide an early alert to the banking organization’s regulator of emerging threats to the banking organization and the broader financial system.
December 11, 2020, Covington Alert
On December 8, 2020, the House passed the National Defense Authorization Act (the “NDAA” or “Act”), which includes over 200 pages of significant reforms to the Bank Secrecy Act (“BSA”) and other anti-money laundering (“AML”) laws that have been working their way through Congress for several years. Despite some remaining objections from President Trump and ...
October 16, 2020, Covington Alert
On September 17 and October 6, 2020, the Commodity Futures Trading Commission (“CFTC” or “Commission”) held open meetings (the “September Meeting” and the “October Meeting,” respectively) to consider a number of final rules, each of which the Commission approved unanimously. The September Meeting considered rules impacting market participants, such as swap ...
January 31, 2020, Covington Alert
On January 30, 2020, the Board of Governors of the Federal Reserve System (“Board”) unanimously approved a final rule that establishes a comprehensive framework for determining whether a company (“investor”) controls another company (“investee”) for purposes of the Bank Holding Company Act (“BHCA”) and Home Owners’ Loan Act (“HOLA”), and clarifies certain ...