Community Banks, Credit Unions, RIAs

What arrives

The Interagency Guidelines
12 CFR Part 364, Appendix B. A written information security program, a risk assessment, service provider oversight, and a report to the board at least annually.
Source
The 36-hour notice
FDIC computer-security incident notification, 12 CFR 304.23. Notice to the primary federal regulator no later than 36 hours after a notification incident is determined.
Source
The ISE
NCUA Information Security Examination procedures, implemented in 2023 to standardize the examination of credit union information security and cybersecurity programs.
Source
The 30-day notice
SEC Regulation S-P amendments, 2024. Notice to affected individuals as soon as practicable, and no later than 30 days after learning of unauthorized access to customer information.
Source
The 72-hour rule
NCUA cyber incident notification, 12 CFR 748.1(c). Notice to NCUA no later than 72 hours after a credit union reasonably believes a reportable cyber incident occurred.
Source
A quiet lobby, lift doors along one wall and a reception desk at the end.

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