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What Banks Should Fear In 2016

This year, financial institutions should prepare to face heightened regulatory scrutiny of their cyber preparedness, says Nixon Peabody's Susan Feibus.


A growing number of sophisticated cyber threats are the top risk for large and midsized banks, according to the Office of the Comptroller of the Currency's fall Semiannual Risk Perspectives. Because of this, one of the top priorities for state and federal regulators this year will be assessing banks' cyber readiness.

Financial institutions that don't have cyber policies and procedures in place may face consequences, says Susan: downgraded safety and soundness ratings or even enforcement action.

A trial lawyer, Susan also advises on privacy, data security and cybersecurity. She spoke recently at two cybersecurity conferences attended by bank senior management and board members, discussing board governance issues.

There's a new cybersecurity assessment tool from the Federal Financial Institutions Examination Council that looks at institutions' risk profile and preparedness, and financial institutions should expect examiners to use it. It's "inescapable" that senior management and boards at banks allocate financial resources and personnel to managing cyber risk in 2016, she says; they neglect that issue at their own risk.