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Updated January 5, 2023

Introduction to Financial Services: Financial Cybersecurity

Cybersecurity is a major concern of financial institutions
and 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, a data breach at insurance company First
American Financial exposed 885 million files with personal
and private financial information; in 2020, a data breach at
Experian exposed 24 million customers' data; and in 2022,
a Block employee downloaded and leaked 8 million
customers' data.
Research suggests that 25% of malware attacks target
financial services companies. Further, the cost of
cybercrime at financial institutions outpaces the cost of
cybercrime to other industries. For example, according to a
2019 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
F  _..T .          -                 7e  o
11.4      1
1  .                        9  >3
oth JQ 3u. .         .$13
s    e              $':l    1  5 
Source: Figure created by CRS, adapted from Accenture, Unlocking
the Value of Improved Cybersecurity Protection, July 15, 2019.
Cybersecurity threats pose operational risk and
reputational risk. Operational risk is the threat tat 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 treat 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 infor ation during a cyberattack, the customer
may lose trust in the institution. Cybersecurity protects
against some aspects of operational and reputational risk.
If te entire system fails to adequately address
cybersecurity concerns, this could lead to systemic risk-
the risk tat 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. Further, the
Financial Stability Oversight Council noted in a recent
annual report that systemic risk may have increased as the
COVID-19 pandemic has increased reliance on technology,
such as remote payment systems.
Federai Po.cy 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
Sections 13(a) and 15(d) of the Securities Exchange Act of
1934 to also file annual reports with the Securities and
Exchange Commission that identify internal and external
risks to the business and the ways that the company guards
against those risks. Bank and thrift holding companies and
insured depositories are required to file similar reports with
their regulators.
The Fair and Accurate Credit Transactions Act (P.L.
108-159) amended the Fair Credit Reporting Act to require
regulatory agencies to develop identity theft guidelines,
which outline patterns, practices, and specific forms of

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