Overview
Title
Proposed Agency Information Collection Activities; Comment Request
Agencies
ELI5 AI
The Federal Reserve Board wants feedback on a plan to keep a rule for banks that says they have to quickly tell them about any big computer problems. People can share their thoughts and concerns about this rule until February 2025.
Summary AI
The Board of Governors of the Federal Reserve System is seeking public comments on a proposal to extend the Computer-Security Incident Notification requirements for three more years without any changes. This rule mandates banking organizations to promptly notify their primary Federal banking regulator of any significant computer-security incidents within 36 hours. The Federal Reserve Board invites feedback on various aspects of the information collection, including its necessity, accuracy, and ways to reduce the burden on respondents. Comments can be submitted until February 4, 2025.
Abstract
The Board of Governors of the Federal Reserve System (Board) invites comment on a proposal to extend for three years, without revision, the Computer-Security Incident Notification (FR 2231; OMB No. 7100-0384).
Keywords AI
Sources
AnalysisAI
The document in question is a notice from the Board of Governors of the Federal Reserve System, inviting public comments on a proposal to extend the Computer-Security Incident Notification requirements for another three years. This regulation compels banking organizations to alert their primary Federal banking regulator within 36 hours of identifying a significant computer-security incident. The Federal Reserve Board is soliciting feedback on the necessity, accuracy, and potential burden of the information collection process related to these notifications.
General Overview
This notice highlights efforts to continue regulatory measures ensuring that significant computer-security events in the banking sector are promptly reported to federal authorities. The importance of such regulations cannot be overstated, given the increasing frequency and sophistication of cyber threats. By maintaining this notification requirement, the Board aims to help mitigate risks to financial stability and consumer protection.
Significant Issues and Concerns
Several concerns warrant consideration:
Definition Ambiguity: The document does not clarify what precisely constitutes a "computer-security incident" or a "notification incident," which might lead to inconsistencies or misinterpretations in compliance obligations among different banking entities.
Burden Estimation: While the notice references methodologies used to estimate the annual burden hours imposed on respondents, it does not outline these calculations in detail. This lack of transparency might create uncertainty about the validity of these estimates.
Cost Analysis: The document does not provide a detailed analysis of potential capital or startup costs associated with compliance. This omission could hinder stakeholders' ability to assess the financial impact fully.
Confidentiality Concerns: There is a lack of specific guidance on protecting confidential information within comments submitted by the public. This could deter entities from providing full and candid feedback.
Complex Language: Some of the terminology may be complex for individuals not versed in regulatory or information technology fields, which could create barriers to understanding and participatory engagement from the general public.
Public Impact
For the general public, the continuation of this regulation underscores the importance of cybersecurity and sound financial oversight. It provides a layer of assurance that measures are in place to respond rapidly to cyber threats, promoting financial system stability and consumer protection.
Impact on Stakeholders
Banking Organizations and Service Providers: These entities are directly affected, as they must ensure they meet the prompt notification requirements. Understanding of the requirements and potential compliance costs is crucial for these stakeholders. The lack of detail in cost analysis and burden estimation could present challenges as they strive to budget and plan processes effectively.
Regulatory Bodies: For agencies overseeing financial regulations, this initiative reflects an ongoing commitment to cybersecurity and operational integrity in the banking sector. Receiving feedback will help them refine and improve the approach to enforcement and policy development.
Consumers and the General Public: They stand to benefit from enhanced protection against the fallout of cybersecurity incidents, which could otherwise threaten personal data security and financial stability.
In summarizing, while the extension of the Computer-Security Incident Notification seems aligned with broader goals of financial system security, attention to specific concerns raised in the notice such as clarity of definitions and transparency of the burden assessment methodology, could enhance compliance and efficacy of the regulation. The public and stakeholders should be encouraged to engage with and respond to this notice to ensure their needs and concerns are addressed.
Issues
• The document does not specify the criteria for determining what constitutes a 'computer-security incident' or a 'notification incident,' which may lead to ambiguity in compliance expectations.
• The burden estimate methodology for the proposed information collection is referenced but not detailed within the document, leaving potential uncertainty about the assumptions and calculations used to arrive at the 'total estimated annual burden hours.'
• There is no detailed cost analysis provided for public comment regarding capital or startup costs, which might affect respondents, potentially making it difficult for stakeholders to assess the full impact of compliance.
• The notice does not specify explicit measures for protecting confidential information submitted as comments, which could be a concern for entities wishing to keep certain submitted information private.
• The language could be considered complex in some areas, potentially making it challenging for those not specialized in regulatory or IT fields to fully understand the requirements and implications.