On October 19, 2016, the Board of Governors of the Federal Reserve System, Office of the Comptroller of the Currency, and Federal Deposit Insurance Corporation released a joint Advance Notice of Proposed Rulemaking (ANPR) requesting public comment on enhanced cybersecurity standards that would apply to certain large, interconnected financial entities as well as the third parties that provide services to such entities. The enhanced cybersecurity standards being considered by the Agencies, if implemented in the form described in the ANPR, would have a substantial effect on the financial services industry and require very significant new efforts from covered entities and their service providers to both implement compliant processes and manage these processes on an ongoing basis.

Our client alert covering the ANPR is available here.