Banking Agencies’ Proposed Cybersecurity Regulations

On Oct. 19, 2016, the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation issued a joint advance notice of proposed rulemaking (“Notice”) inviting public comment on cybersecurity regulations and guidance designed to improve the safety and soundness of the U.S. financial system. In this article,  former Schulte attorneys Joseph Vitale and Michael Yaeger and associate Noah Gillespie discuss the Notice’s two-tiered framework that would impose standards on covered institutions.