WASHINGTON—NCUA’s proposed rule establishing a 72-hour period for credit unions to provide notice of a reportable cyber incident would likely add more administrative burden to credit unions, NAFCU is saying.
NAFCU wrote to the NCUA to offer its recommendations on NCUA’s proposed rule.
In the letter, NAFCU Senior Counsel for Research and Policy Andrew Morris provided nine recommendations it said would ease the burden of this rule, including:
- Recognize a compliance safe harbor for a credit union that makes good faith efforts to perform a reasonable assessment of a cyber incident
- Clarify core terminology
- Streamline communication with supervisory teams
- Clarify the relationship between overlapping reporting standards
- Avoid conflict with current and future cyber incident reporting requirements
- Recognize a credit union has the final say to report any third-party cyber incident
- Calibrate reporting thresholds to avoid requiring a credit union to report incidents that happen outside the credit union’s domain
- Ensure proper coordination exists with other federal regulators
- Clearly state that any cyber incident notifications given to the NCUA are confidential
- Reducing Overlap
‘Improve Resilience’
NAFCU said it believes these recommendations would improve clarity and reduce overlap if the NCUA decides to proceed with a final rule. The association added that it also requests the agency use the information it collects from credit unions to “improve the security and resilience of the industry,” as well as hold more cybersecurity briefings for credit unions.
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