More about John Moeller
Blog Posts by John Moeller:
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Will the Cyber Incident Reporting for Critical Infrastructure Act of 2022 help or confuse Financial Institutions?
Recent legislation drives 72-hour timeline for notification of data breach and 24-hour notification of ransomware payment.
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Engaging and Managing your MSP
Over the years, our financial institution’s practice has seen numerous instances where financial institutions switch Managed Service Providers (MSPs) out of frustration due to MSP underperformance, out of scope costs, and lack of industry expertise. The process to select the right MSP for your financial institution requires confirmation of the MSP’s industry expertise, an understanding of contract features, and greater vendor oversight of the MSP.
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It is Not Too Late to Enhance Your Pandemic Plan
As we continue to navigate the challenging times brought on by COVID-19, financial institutions have been rightly focused on employee safety, customer service, and business continuity. But, regulatory statements released to date should remind all institutions of the importance of pandemic planning even as we are in the midst of the current crisis. Just because institutions have quickly adapted to the new realities they are facing, does not mean that additional challenges aren’t around the corner.
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New York State Guidance on Pandemic Planning May Signal Trend
On March 10, 2020, the New York Department of Financial Services (“NY DFS”) issued four separate industry letters providing guidance to state regulated financial institutions. These letters establish additional requirements to develop and maintain preparedness plans and complete other actions relating to COVID-19.
Since New York is currently the hardest hit state by the virus, these early actions could signal a trend that other agencies will follow as the outbreak progresses.