2003 Comment Letters
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Date Mailed:
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October 10, 2003
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Topic:
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Interagency Guidance on Response Programs for Unauthorized Access to Customer Information and Customer Notice (PDF,190KB) |
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The Federal Reserve Board, the Office of the Comptroller of the Currency, the Office of Thrift Supervision, and the Federal Deposit Insurance requested comment on their proposed guidance concerning customer notification. The letter from President Moskow explains that the Federal Reserve Bank of Chicago agrees that the provision of guidance is preferred over the imposition of uniform rules, giving financial institutions flexibility with respect to their size and complexity. In order to reduce regulatory and compliance costs to financial institutions in creating response programs, representatives from the Chicago Fed submitted recommendations intended to clarify the proposed guidance. In the comment letter, the Chicago Fed delineates changes to the guidance that they consider necessary and appropriate regarding the following
- when customer notification is required
- the definition of "sensitive" information
- the timing requirements for investigation and disclosure
- what constitutes an investigation of a security breach
- the meaning of "secure" accounts.
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The submission includes a letter from President Moskow accompanied by a paper authored by an interdisciplinary team that was led by Anna Paulson and included Kevin Hilbert, Paul Neff, and Steve Kuehl.
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