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Updated January 13, 2022

Introduction to Financial Services: Financial Cybersecurity

Cybersecurity is a major concern of financial institutions
and federal financial regulators. Recent data breaches at
large financial institutions have increased concerns about
the privacy and security of consumer financial information.
For example, in 2019, insurance company First American
Financial experienced a breach that exposed 885 million
files, including Social Security Numbers and driver's
license and account information.
Financial institutions seek to prevent electronic theft of
money and other assets, as cyberspace disruptions, such as
denial-of-service attacks, could interrupt or shut down their
businesses. According to a private study, the per-company
cost of cybercrime is over $18 million for financial services
companies, around 40% higher than the average cost for
other sectors, as illustrated in Figure 1.
Figure I. Costs of Cybercrime Across Sectors
by sector, $ in millions
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the Value of Improved Cybersecurity Protection, July 1 5, 20 19.
Cybersecurity threats pose operational risk and
reputational risk. Operational risk is the threat that an
event-such as a natural disaster, pandemic, or
cyberattack-limits or completely obstructs an institution's
ability to do business. Reputational risk is the threat that
customers will take their business elsewhere based on the
actions of or associated with a financial institution. For
example, if a financial institution fails to secure a
customer's information during a cyberattack, the customer
may lose trust in the institution. Cybersecurity is a way to
protect against some aspects of operational and reputational
risk.
If the entire system fails to adequately address
cybersecurity concerns, this could lead to systemic risk-
the risk that a cybersecurity incident would destabilize the
financial system. For example, in a highly interconnected
financial system, a cybersecurity incident at one of the

major banks or payment networks could adversely affect
operations at many other financial institutions. The
Financial Stability Oversight Council (FSOC) has identified
three channels through which a cybersecurity event could
threaten the stability of the U.S. financial system:
1. An incident could disrupt a key financial service or
a financial market utility for which there are few
substitutes (e.g., the central bank, exchanges, and
payment clearing and settlement institutions).
2. An incident could cause a loss of confidence
among a broad set of customers or market
participants.
3. An incident could compromise the integrity of
critical data, rendering information critical to
financial firms either inaccurate or unusable.
Further, FSOC's 2020 Annual Report notes that systemic
risk may have increased as the COVID-19 pandemic has
increased reliance on technology, such as remote payment
systems.
Federal Poiy Approaches
The federal government has increasingly recognized the
importance of cybersecurity in the financial services
industry, and federal financial regulators each have a role in
cybersecurity. Numerous laws cover aspects of
cybersecurity for different industries. Some of these laws
contain specific provisions that require financial regulators
to implement rules that establish cybersecurity standards for
financial institutions, and they provide regulators the
authority to supervise these institutions for compliance with
such standards. Other laws provide broad authority to
regulators to regulate and supervise financial institutions for
safety and soundness. Financial regulators rely on these
broad authorities to shape cybersecurity policies for the
institutions they regulate.
The Gramm-Leach-Bliley Act of 1999 (GLBA; P.L. 106-
102) is the most comprehensive of these laws and directs
financial regulators to implement disclosure requirements
and security measures to safeguard private information.
GLBA provides a framework for regulating data privacy
and security practices for financial institutions. This
framework is built upon two pillars: (1) privacy standards
that impose disclosure limitations on financial institutions
concerning consumers' information and (2) security
standards that require institutions to implement certain
practices to safeguard information from unauthorized
access, use, and disclosure. The rules implementing this
framework are known as the Privacy Rule (Regulation P)
and the Safeguards Rule.
The Sarbanes-Oxley Act of 2002 (P.L. 107-204) contains
provisions requiring a corporation that files reports under

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