Overview
Title
Agency Information Collection Activities: Information Collection Renewal; Submission for OMB Review; Computer-Security Incident Notification
Agencies
ELI5 AI
The OCC wants to hear what people think about their rule that banks must tell them quickly if something bad happens to their computers that makes the bank stop working well. They want to make sure it takes as little time and work as possible to do this, and people have until March 3, 2025, to share their thoughts.
Summary AI
The Office of the Comptroller of the Currency (OCC) seeks public comments on renewing its information collection titled "Computer-Security Incident Notification." This information gathering is part of an ongoing effort to minimize paperwork and reduce respondent burden in line with the Paperwork Reduction Act of 1995. The OCC requires banking organizations to inform them within 36 hours of a significant computer-security incident that disrupts their operations. Comments on this proposal can be submitted until March 3, 2025.
Abstract
The OCC, as part of its continuing effort to reduce paperwork and respondent burden, invites comment on a continuing information collection, as required by the Paperwork Reduction Act of 1995 (PRA). In accordance with the requirements of the PRA, the OCC may not conduct or sponsor, and the respondent is not required to respond to, an information collection unless it displays a currently valid Office of Management and Budget (OMB) control number. The OCC is soliciting comment concerning the renewal of its information collection titled, "Computer-Security Incident Notification." The OCC also is giving notice that it has sent the collection to OMB for review.
Keywords AI
Sources
AnalysisAI
The document in question is a notice issued by the Office of the Comptroller of the Currency (OCC), a bureau within the U.S. Department of the Treasury. The OCC is inviting public comments on its proposal to renew an information collection related to "Computer-Security Incident Notification." This initiative is part of a broader mission aimed at minimizing paperwork and reducing the reporting burden on respondents, consistent with the Paperwork Reduction Act of 1995.
Summary
The OCC requires banking organizations to report significant computer-security incidents within 36 hours of occurrence. Such incidents should be materially disruptive to their operations. The public is invited to submit comments on this proposal until March 3, 2025. The objective is to ensure that information collected is necessary and does not impose undue burdens on stakeholders.
Significant Issues and Concerns
The document is laden with legal and technical jargon, likely making it challenging for laypeople to fully grasp the nuances, which might limit public participation during the comment period. Important concepts such as "notification incident" and what qualifies as a "material disruption" are not sufficiently explained. This complexity may lead to varied interpretations and potentially inconsistent reporting across banking organizations.
Moreover, the process by which the total annual burden of 2,796 hours was calculated remains unclear, creating ambiguity for entities attempting to understand compliance demands. Additionally, the notice does not elaborate on possible penalties for failing to report incidents within the stipulated timeframe, possibly leading to non-compliance.
Further, asking for comments through physical mail or fax seems outdated, particularly in a digitally-centric context, and might deter engagement.
Broad Public Impact
Ensuring secure banking operations is crucial for public confidence in financial institutions. Thus, requirements like these from the OCC are important for safeguarding personal financial data from breaches. However, the complexity and lack of clarity could dissuade individuals and organizations from participating in the comment process, potentially stifling valuable feedback.
Impact on Specific Stakeholders
For banking organizations and service providers, this notice implies a renewed commitment to communicate significant security threats promptly. While this can aid in maintaining systemic financial stability, the lack of specificity about terms used might result in inconsistent compliance efforts.
For customers, the regulations aim to reassure that there are mandatory protective measures in place against cyber threats. However, the efficacy of these assurances hinges on the clarity and strict adherence to these regulatory norms by banks.
In conclusion, while the OCC's goals align with fostering a secure financial ecosystem, clearer communication and more considerate mechanisms for feedback collection may enhance compliance and public trust.
Issues
• The document contains a complex regulatory language that may be difficult for the general public to understand, potentially reducing the effectiveness of the public comment period.
• There is no detailed explanation or example provided for what constitutes a 'notification incident', which may lead to inconsistent interpretations by different banking organizations.
• The document lacks specific examples or scenarios that illustrate what is meant by material disruption or degradation of services, which might help clarify the criteria for reporting incidents.
• The estimated burden section does not explain how the total annual burden of 2,796 hours was calculated, leaving ambiguity in understanding the burden on respondents.
• The document does not specify if there are penalties for failing to report a computer-security incident within the specified timeframe, which might lead to non-compliance by banking organizations.
• The reliance on a physical address and fax for submitting comments may appear outdated, given the digital context of the information collection.