CSIN Incident Response Planning

You don’t have to be the target of a cyberattack to be a victim. In today’s digitally connected world, regulators have come to understand that the impact of a security threat can far outweigh the intention. Regulations such as the Computer-Security Incident Notifications (CSIN) rule attempt to create urgency and transparency around such risks by requiring financial institutions to report security incidents within 36 hours after a determination has been made that a notification incident has occurred. 

For security, privacy, and incident response teams, the window to conduct effective risk assessment and reporting is limited and can create pressure for teams managing compliance requirements.

As new regulations aim at consumer and investor protections, the increased scrutiny of risk management, incident response, and business continuity planning is now a Board-level issue, and cyber event reporting and risk mitigation are crucial concerns for boards of directors across industries. How you plan to communicate risks during incident response is integral to compliant decision-making and escalation processes for CSIN reporting.

In this blog, we’ll explore best practices for ensuring a consistent, documented, and repeatable process to manage cyber risk, communicating incidents with stakeholders, and building trust with regulators.

Incident Response in Organizational Risk Management

Incident response is more than a checklist; it’s a comprehensive organizational process that integrates into the broader enterprise risk management framework. 

Effective cyber risk management requires the entire company to ensure business resilience with collaboration across all enterprise risk management leaders. Establishing a robust incident response plan is essential for protecting your organization’s assets, maintaining customer trust, and ensuring compliance with regulations like CSIN.

Planning for CSIN Incident Response

Incident response is designed to prevent or limit the damage, cost, and duration of a security or privacy incident, including the event’s impact and meeting regulatory compliance requirements.

After an incident occurs, your team will be racing against time-bound reporting regulations, so preparation is key to effective incident response. This phase focuses on equipping your incident response team with the necessary tools, policies, and training to handle incidents efficiently.

A closer look at each incident response step reveals how they work, individually and collectively, to empower (or inhibit) a company’s response.

1. Establish a consistent cyber risk management and incident response process. 

This process should operationalize a risk matrix against urgent cyber events to ensure a consistent, documented, and repeatable process for assessing risks, communicating with stakeholders, and building trust with regulators. 

Given the stress and importance of cyber risk management, you can reduce the risk of subjective decision-making and human error by automating risk assessments and notification determinations with purpose-built solutions.

2. Define organizational risk matrices. 

Each organization has a unique risk appetite and should create its own decision-making criteria for the intake and assessment of risk. For financial institutions, the risk from a cyber attack can come in many forms, including direct harm to customers, business continuity lapses that impact the entire organization, or fines from non-compliance that include financial and reputational harm. 

Start crafting your organizational risk matrices with a map of applicable regulations and create guides for each to help establish an internal process for triaging, escalation, and reporting requirements.

For organizations operating across sectors, keeping up with new and emerging regulations can be more challenging but software solutions exist to simplify risk management and provide consistent, repeatable, and documented risk management decision-making.

3. Conduct a risk assessment and communicate with affected parties if a cyberattack rises to the level of notification. 

According to the CSIN rule, a notifiable incident is “an occurrence that results in actual harm to the confidentiality, integrity, or availability of an information system or the information that the system processes, stores, or transmits.”

These generally include significant computer security incidents that disrupt or degrade, or are reasonably likely to disrupt or degrade, the viability of the banking organization’s operations, result in customers being unable to access their deposit and other accounts or impact the stability of the financial sector. However, each incident is unique and requires the same level of attention in risk assessment. 

In the event of a notifiable incident, notify the OCC, or your primary regulator, as soon as possible, but no later than 36 hours after determining that a computer security incident has occurred. This notification should be sent to the appropriate OCC supervisory office or OCC-designated point of contact via email, telephone, or other methods prescribed by the OCC.

For bank service providers, notify at least one bank-designated point of contact at each affected customer bank as soon as possible when a computer security incident has materially disrupted or degraded, or is reasonably likely to disrupt or degrade, covered services provided to the bank for four or more hours. If a designated point of contact is not provided, notify the bank’s chief executive officer and chief information officer, or two individuals with comparable responsibilities.

Detailing these plans before an attack can make all the difference in meeting compliance with regulatory reporting obligations such as CSIN.

4. Translate complex technical data into relevant terms for the board. 

Synthesizing technical know-how into relevant terms and finding common ground around a goal of risk mitigation can help managers effectively communicate with stakeholders. Connect cyber events to financial impacts and establish clear roles and responsibilities within response teams.

5. Foster collaboration

Cyber risk management requires the entirety of a company to ensure business resilience with an inclusive message of collaboration that encompasses all enterprise risk management leaders. 

6. Regularly test and update your communications plan.

Conduct frequent training and simulations to ensure your team is prepared to respond effectively to incidents. Update your incident response plan based on lessons learned from past incidents and changes in the threat and regulatory landscape.

The Board’s Role in Cybersecurity

Cyber event reporting and risk mitigation are now board-level issues across industries. Effective reporting will require connecting cyber events to financial impacts and establishing clear roles and responsibilities within response teams. By building rapport with stakeholders and ensuring they understand the potential financial and operational impacts of cyber incidents, CISOs can drive better risk management and incident response strategies.

In today’s landscape of increasing cyber threats, a well-defined and regularly tested incident response plan is crucial for banks. By understanding the requirements of the CSIN regulation and integrating incident response into your broader organizational risk management framework, you can protect your institution, maintain customer trust, and ensure compliance. Taking these steps will not only help you meet regulatory obligations but also strengthen your organization’s resilience in the face of evolving cyber threats.