Independent Banker - March 2021 - 39

2. Promote a self-defense strategy.
Reach out to other community banks
in the area and coordinate incident
response, cyber breach and disaster
recovery plans. Coordinating banks
can help one another, providing stopgap
support as needed, in the event
one of them falls victim to a disruptive
cyber event.
Like drills in sports, you need to
regularly practice your incident
response plans so you are
3. Recognize the emotional wear
of a breach. No one really talks
about it, but responding to a major
cyber event can be emotionally
exhausting for bank staff , including
senior leadership. That can reduce the
eff ectiveness of the bank's response.
If your bank has recently retired
executives or board members, it can
be worthwhile to include them in the
response plan.
4. Talk to your regulators and
law enforcement ahead of time.
If you've never had to notify your
regulators about a cyber incident or
engage law enforcement, now is the
time to practice. Make sure you and
your staff are comfortable having
these conversations and know who to
speak with.
Who is protecting banks' data?
Community banks are among
the best-protected and resilient
businesses in the country. The
Gramm-Leach-Bliley Act (GLBA)
and other supervisory regulations
require fi nancial institutions to
protect nonpublic, sensitive customer
data (NPII).
The same cannot be said for
retailers, technology companies,
fi ntechs and others that process
or store consumer fi nancial data.
That makes customer data stored
in other, more vulnerable locations
an attractive target for hackers. Yet
the work of sorting out the results
of disclosed data often falls back on
prepared to respond to cyber
incidents immediately.
fi nancial institutions. ICBA will
continue to advocate for the security
of customer data. Participants in
the payments system and all entities
with access to customer fi nancial
information should be subject
to and maintain well-recognized
standards similar to those detailed
in the GLBA.
Community banks are required to
submit sensitive bank information
during exams and when fi ling
suspicious activity reports (SARs).
ICBA advocates that community
Do you have
questions?
Regulators have asked
that community banks
with questions about the
SolarWinds attack and
government breaches reach
out to their regulator directly.
Regulators are available to
discuss the breach's impact
and provide information on
their status and security.
ICBA is also ready and
available to ask regulators
questions on behalf of
community banks.
banks should not have liability
in the event of a breached
government system.
The Offi ce of the Comptroller of
the Currency (OCC), Federal Deposit
Insurance Corporation (FDIC) and
Federal Reserve Board are soliciting
comments on a proposed rule that
would require banks to notify their
federal regulators within 36 hours
of any computer-security incident.
While ICBA welcomes any eff ort by
the supervisory agencies to work in
partnership with community banks
and provide them with resources
to respond to cyber events, we are
concerned about a new regulatory
burden when community banks
are already among the most
highly regulated when it comes to
information security.
In the months ahead, ICBA
will remain a valuable source
of information related to the
SolarWinds breach and other
cybersecurity issues while working
to ensure breaches at other entities
do not become the burden of
community banks. 
Joel Williquette (joel.
williquette@icba.org) is
ICBA's senior vice president of
operational risk policy
independentbanker.org Q 39
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Independent Banker - March 2021

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