Business Regulation & Regulated Industries

Editors (7)

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McGlinchey Stafford, PLLC

Lynette Hotchkiss

Executive Editor, Business Regulation & Regulated Industries
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Carlton Fields

Thomas F. Morante

Contributing Editor, Business Regulation & Regulated Industries
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Davis Polk

Andrew B. Samuel

Contributing Editor, Business Regulation & Regulated Industries
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Covington and Burling

Lucille C. Bartholomew

Contributing Editor, Business Regulation & Regulated Industries
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Core States Group

Dredeir Roberts

Contributing Editor, Business Regulation & Regulated Industries
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The Arefin Law Office

D. Sharmin Arefin

Contributing Editor, Business Regulation & Regulated Industries
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Troutman Pepper Hamilton Sanders LLP

Barbara T. Sicalides

Contributing Editor, Business Regulation & Regulated Industries

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MONTH-IN-BRIEF (Nov 2021)

[lwptoc]

Banking Law

Federal Agencies Issue Final Rule on Computer-Security Incident Notification Requirements for Banking Organizations

By Christopher Greenidge, McGlinchey Stafford, PLLC

On November 18, 2021, the Office of the Comptroller of the Currency (OCC), the Federal Reserve Board, and the Federal Deposit Insurance Corporation (FDIC) announced the adoption of a final rule that requires a banking organization to notify its primary federal regulator of a significant computer-security incident within 36 hours after the organization determines that the incident has occurred.

The rule would also require a bank service provider to notify each affected banking organization customer as soon as possible when the bank service provider determines that it has experienced a computer-security incident that has caused, or is reasonably likely to cause, a material service disruption or degradation for four or more hours.

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