Financial Institutions Require More Oversight Of Cybsersecurity Risk Under NYDFS

The New York Department of Financial Services (NYDFS) has published a proposal to amend its cybersecurity rules, which will require regulated companies to notify the NYDFS of a third-party cybersecurity incident within 72 hours.

A draft version of the proposal released earlier this year required financial institutions to notify regulators about such incidents within 72 hours. This newer proposal, includes this notice requirement, along with an amendment that notice be provided to NYDFS within 24 hours of making a […]

By | November 15th, 2022 ||

Central Banks Should Consider Climate And Biodiversity Shocks When Stress Testing Financial Institutions

Sylvie Goulard, Deputy Governor of the Banque de France, the French central bank, stated in a speech on October 24 that central banks need to take more aggressive action regarding nature-related risk. She posited that “monetary assessments of ecosystem services have many limitations,” in part because of their complexity and also because “shocks” in one sector can have significant impacts on other sectors. As a result, she proposed that “the best risk mitigation strategy is to […]

By | November 12th, 2022 ||

Financial Institutions Advisory: NCUA Issues Proposed Amendment To Subordinated Debt Rule

On Wednesday, October 5, 2022, the National Credit Union Administration (“NCUA”) issued a proposed rule (“Proposed Rule”) to amend its Subordinated Debt Rule (the “Sub Debt Rule”), which they previously published in December 2020 and which became effective on January 1, 2022.1 Under the Sub Debt Rule, credit unions designated as low-income credit unions (“LICUs”), complex credit unions, and new credit unions are permitted to issue Subordinated Debt for purposes of regulatory capital treatment. The NCUA must […]

By | November 8th, 2022 ||