The recent disruption caused by CrowdStrike has been a wake-up call for financial institutions, highlighting that no cybersecurity system is entirely foolproof. However, this realisation doesn’t lessen the need for rigorous preparation against potential cyber threats.
What Happened with CrowdStrike?
CrowdStrike, a well-known cybersecurity company based in Austin, Texas, recently faced a major issue that caused extensive system crashes. The problem originated from a software update to their Falcon Sensor, which led to a "logic error." This error caused systems to crash, showing the infamous "Blue Screen of Death" (BSOD). The company later revealed that a pre-deployment test, meant to catch such errors, failed, leading to widespread issues.
This incident impacted various organisations, including big names like ICE Mortgage Technology, Fifth Third Bank (with $214 billion in assets), TD Bank, and Canandaigua National Bank in New York, which holds $5 billion in assets.
The Need for Better Planning
Dave Martin, founder of the advisory firm BankMechanics, emphasised that while such events are often discussed in theoretical terms when planning for worst-case scenarios, they can quickly become real, underscoring the ardent need for being well-prepared.
According to Martin, this event has likely prompted bank leaders around the world to focus even more on their contingency plans and backup strategies. The fact that this outage affected so many organisations shows just how unpredictable such crises can be.
As cybersecurity threats become more common, financial institutions are increasingly focused on their defences. The risks of not being adequately prepared are growing. For example, after a cyberattack in June, Patelco Credit Union in California, which manages $9.6 billion in assets, is now facing multiple lawsuits. These lawsuits claim that the credit union did not properly secure sensitive data, such as Social Security numbers and addresses.
Andrew Retrum, a managing director at Protiviti, a consulting firm specialising in technology risk and resilience, pointed out that while organisations face numerous potential threats, they should focus on creating strong response and recovery strategies for the most likely negative outcomes, like technology failures or site unavailability.
Preparing for Future Cyber Incidents
Experts agree on the importance of having detailed action plans in place to restore operations quickly after a cyber incident. Kim Phan, a partner at Troutman Pepper who specialises in privacy and data security, advises financial institutions to be ready to switch to alternative systems or service providers if necessary. In some cases, this might even mean going back to manual processes to ensure that operations continue smoothly.
Phan also suggests that financial institutions should manage customer expectations, reminding them that the convenience of instant online services is not something that can always be guaranteed.
The CrowdStrike outage is a recurring reminder of how unpredictable cyber threats can be and how crucial it is to be prepared. Financial institutions must learn from this incident, regularly updating their security measures and contingency plans. While technology is essential in protecting against cyber threats, having a solid, human-driven response plan is equally important for maintaining security and stability.
By looking at past cyber incidents in the banking sector, we can draw valuable lessons that will help strengthen the industry's overall defences against future attacks.
The Securities and Exchange Commission (SEC) is demanding financial institutions to report security vulnerabilities within 30 days of discovering them.
On Wednesday, the SEC adopted revisions to Regulation S-P, which controls how consumers' personal information is handled. The revisions require institutions to tell individuals whose personal information has been compromised "as soon as practicable, but no later than 30 days" after discovering of illegal network access or use of consumer data. The new criteria will apply to broker-dealers (including financing portals), investment businesses, licensed investment advisers, and transfer agents.
"Over the last 24 years, the nature, scale, and impact of data breaches has transformed substantially. These amendments to Regulation S-P will make critical updates to a rule first adopted in 2000 and help protect the privacy of customers’ financial data. The basic idea for covered firms is if you’ve got a breach, then you’ve got to notify. That’s good for the investor,” said SEC Chair Gary Gensler.
Notifications must describe the occurrence, what information was compromised, and how impacted individuals can protect themselves. In what appears to be a loophole in the regulations, covered institutions are not required to provide alerts if they can demonstrate that the personal information was not used in a way that caused "substantial harm or inconvenience" or is unlikely to do so.
The revisions compel covered institutions to "develop, implement, and maintain written policies and procedures" that are "reasonably designed to detect, respond to, and recover from unauthorized access to or use of customer information." The amendments include:
The standards also increase the extent of nonpublic personal information protected beyond what the firm gathers. The new restrictions will also apply to personal information received from another financial institution.
SEC Commissioner Hester M. Peirce expressed concern that the new regulations could go too far.
"Today’s Regulation S-P modernization will help covered institutions appropriately prioritize safeguarding customer information," she said. "Customers will be notified promptly when their information has been compromised so they can take steps to protect themselves, like changing passwords or keeping a closer eye on credit scores. My reservations stem from the rule's breadth and the likelihood that it will spawn more consumer notices than are helpful."
Regulation S-P has not been substantially modified since its adoption in 2000.
Last year, the SEC enacted new laws requiring publicly traded businesses to disclose security breaches that have materially affected or are reasonably projected to damage business, strategy, or financial results or conditions.
This mandate requires the creation, execution, and upkeep of an extensive security policy to protect consumer data, and it applies to businesses including payday lenders, auto dealers, and mortgage brokers.
The Safeguards Rule, which required financial institutions to report security breaches found in their systems as soon as they occur, was recently amended by the federal government. Organizations must notify the Federal Trade Commission (FTC) "as soon as possible," but no later than 30 days, of any security issue involving the information of 500 or more customers.
It has been made mandatory for organizations to report the FTC in case any malicious or unauthorized entity gains illicit access to unencrypted customer data. However, this requirement is only applicable if the data is encrypted and hackers have obtained access to the encryption keys.
From April 2024, the new regulation will go into effect 180 days after it is published in the Federal Register.
FTC further informs that following the discovery of a security incident, non-banking financial institutions will have to use the FTC's online site to report pertinent information to the commission. The identity and contact details of the reporting institution, the number of customers affected, a description of the data disclosed, the date of exposure, and the length of the incident should all be included in a thorough breach report.
Moreover, the amendment will also enable firms to notify the FTC in case the public disclosure of the breach jeopardizes their investigation or national security. An official from law enforcement may as well ask for an additional 60-day delay before making the information public.
The FTC's Bureau of Consumer Protection head, Samuel Levine, stressed that businesses that are entrusted with private financial data must be open and honest "if that information has been compromised." These businesses should be given "additional incentive" by the new disclosure obligation to actually protect the data of their customers.
In October 2021, the FTC released revised guidelines to improve data security while also inviting public feedback on a proposed supplemental amendment to the data breach reporting standards. The new amendment was ultimately accepted by a unanimous vote of three to one.