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               Researh Sevice






Cybersecurity: Recent Policy and Guidance on

Federal Vulnerability Disclosure Programs



September 8, 2020

The Trump Administration has released policy and guidance on vulnerability disclosure programs
(VDP) for federal agencies. VDPs help organizations secure their information technology (IT) by
allowing the public to discover and report weaknesses in systems in the hope that the organization will
mitigate the vulnerabilities. Vulnerabilities can be exploited by malicious actors to compromise systems,
which may lead to data breaches.
On September 2, 2020, the Office of Management and Budget (OMB) released Memorandum M-20-32
on Improving Vulnerability Identification, Management, and Remediation and the Cybersecurity and
Infrastructure Security Agency (CISA) released Binding Operational Directive 20-01 (BOD) to Develop
and Publish a Vulnerability Disclosure Policy.


Policies

Memorandum M-20-32 establishes the policy of a federal VDP and agency responsibilities. The
memorandum states that a VDP includes traditional vulnerability disclosure policies (i.e., an open
program where the public can find vulnerabilities in IT systems), bug-bounty programs (i.e., a program in
which public and vetted researchers are paid to find vulnerabilities), and penetration testing (i.e., a private
program where researchers are hired to discover ways to attack systems). M-20-32 states federal agencies
shall:
    *  Create plain-language VDP policies that articulate which systems are in bounds for
       research and what activities researchers may perform to discover vulnerabilities.
    *  Declare that good-faith research (as opposed to probing for malicious purposes) is
       authorized; assuring that the agency will not pursue legal action against the researcher.
    *  Create a reporting mechanism for identified vulnerabilities.
    *  Create a process for timely agency feedback to researchers on report status.
    *  Create a process to inform agency system owners of reported vulnerabilities.
    *  Separate reporting metrics on VDP use from reporting on cybersecurity incidents.
                                                               Congressional Research Service
                                                                 https://crsreports.congress.gov
                                                                                     IN11497

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