ARTICLE
19 August 2021

24 Hour Cyber Incident Notification Requirement Is Too Short!

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Foley & Lardner

Contributor

Foley & Lardner LLP looks beyond the law to focus on the constantly evolving demands facing our clients and their industries. With over 1,100 lawyers in 24 offices across the United States, Mexico, Europe and Asia, Foley approaches client service by first understanding our clients’ priorities, objectives and challenges. We work hard to understand our clients’ issues and forge long-term relationships with them to help achieve successful outcomes and solve their legal issues through practical business advice and cutting-edge legal insight. Our clients view us as trusted business advisors because we understand that great legal service is only valuable if it is relevant, practical and beneficial to their businesses.
BankInfoSecurity.com reported "that financial institutions "will have limited information on an event" within 24 hours.
United States Technology

BankInfoSecurity.com reported "that financial institutions "will have limited information on an event" within 24 hours. They add that the details of cyber intrusions involving nation-states or advanced persistent threat groups cannot be adequately gathered within 24 hours, given the need for assistance from federal agencies."  The August 17, 2021 report entitled "Banking Groups Object to Breach Notification Bill Provisions" included these comments:

The American Bankers Association, Bank Policy Institute and Consumer Bankers Association sent a letter to the U.S. Senate Intelligence Committee recommending that the Cyber Incident Notification Act of 2021 be amended to include a 72-hour notification requirement, rather than 24 hours.

The initial stages of an incident response require 'all hands on deck' to focus immediately on understanding the incident and implementing mitigation and response measures,...

Filing notification reports within 24 hours of incident discovery would result in "premature" and "erroneous" reports, they contend.

How much do we really know in 72 hours?

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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