Posts by: Jason M. Halper

New Guidance for Financial Institution Directors and Officers In Cybersecurity Preparedness

Financial Institutions

Earlier this summer, the Federal Financial Institutions Examination Council (FFIEC) released its highly anticipated Cybersecurity Assessment Tool (Assessment), which is designed to assist financial institutions in identifying and assessing risks and weaknesses in, and the overall maturity of, their cybersecurity preparedness programs.  Financial Institutions’ management, directors, in-house counsel, and regulatory/compliance personnel need to be aware of this development.  Now there is increased guidance on the type of cybersecurity systems and procedures that need to be implemented to satisfy post-hoc regulatory or judicial scrutiny.  This guidance may also impact how regulators, or in the event of a problem, courts hearing civil lawsuits, assess both the institution’s level of preparedness and how the company’s directors and officers discharged their responsibilities in creating and maintaining cybersecurity measures.

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