The Clearing House (TCH) has submitted a comment letter to the Federal Reserve Board of Governors, Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency responding to the agencies’ request for comment on the Enhanced Cyber Risk Management Standards advanced notice of proposed rulemaking. TCH and its members share the goals of cyber resiliency and recognize the benefits of revisiting and strengthening the existing cyber security regulatory framework. TCH recommends, however, that before proceeding with new requirements, the agencies should focus on consolidating existing standards and work with industry stakeholders to assess and close gaps in the current regulatory framework, which involves a plethora of existing standards that have not been harmonized. Further, due to the evolving nature of cyber risks, TCH recommends that the agencies issue flexible, risk-based objectives in the form of guidance or policy statements rather than binding standards.
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