Bob Dix a letter from the American Bankers Association (ABA) to the White House Office of the National Cyber Director (ONCD), raising concerns over

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Bob Dix a letter from the American Bankers Association (ABA) to the White House Office of the National Cyber Director (ONCD), raising concerns over the regulatory overload of cyber regulation on the industry; the need for regulatory harmonisation across Federal Agencies and coordinated approach to common standards and frameworks to support effective risk management; regulatory oversight and assurance; and a request that regulators have the necessary skills to oversight cyber risk of ABA members.

Bob, we held several 1:1 meetings with ONCD in 2022 and 2023. On the need for the harmonisation and reciprocity of cybersecurity standards, frameworks, oversight and assurance between federal agencies and between the U.S and partner nations. Needed to reduce duplication, regulatory burden, harmonisation of oversight and assurance, provide clarity for audit.

Regulatory harmonisation within the U.S and between the U.S and its international partners is critical to both effective cybersecurity risk regulatory compliance and international trade. Systemically important financial institutions are required to manage risk under operational risk management oversight, or risk increased regulatory capital allocation by regulators. As cyber regulation increases across the U.S and EU, financial institutions are required to demonstrate their management of cyber risk. A risk that they are experienced in managing.

Only challenge is in general federal regulators do not set standards or frameworks, with the exception of FISMA, or the DoD DFARS program. But that does not prevent covered organizations with demonstrating cybersecurity risk management compliance.

A challenge both regulators and covered entities face is the lack of qualified and experienced resources required to implement, oversight and assure cybersecurity risk management. There is simply not enough resources and those in the market will migrate towards higher paying jobs in Financial services over the regulator.

Ted Dziekanowski Brian D. McCarthy Rachel V. Rose, JD, MBA

#theagustagroup #cybersecurity #cyberriskmanagement

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Cyber Risk Management, Cybersecurity, Regulation & Compliance

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