RBNZ launched consultation on the guidance for what regulated entities should consider when managing cyber resilience. The draft guidance, which is open for feedback until January 29, 2021, outlines the expectations of RBNZ around cyber resilience and draws heavily from leading international and national cybersecurity standards and guidelines. RBNZ will publish a summary of submissions and final guidance in March or April 2021. RBNZ is also developing a detailed framework for information gathering and sharing, for which it plans to consult stakeholders in mid-2021.
The guidance has four parts—namely, governance, capability building, information sharing, and third-party management. Third-party management is an area of growing importance and the guidance includes a special subsection on the use of cloud computing services in light of the rapid adoption of cloud services by financial sector firms. The guidance is aligned with international standard and guidelines on cyber resilience and provides a set of high-level principle-based recommendations. The draft cyber risk management guidance would apply to all entities RBNZ regulates. This includes registered banks, licensed non-bank deposit-takers, licensed insurers, and designated financial market infrastructures. The consultation paper also seeks feedback on how information gathering and sharing by RBNZ with relevant public-sector bodies can help to build cyber resilience.
The consultation paper discusses views of RBNZ on a collaborative approach to information gathering and sharing. In the multi-agency landscape, RBNZ plans to promote information gathering and sharing with other relevant government agencies (for example, National Cyber Security Center, Computer Emergent Response Team NZ, and the Financial Market Authority). RBNZ considers that there are merits in following the broad pattern observed in the international practices of establishing a cyber data collection. As a principle, RBNZ will tailor reporting requirements to ensure they stay relevant and minimize the reporting burden. At a very high level, this includes:
- A regular but fairly infrequent data collection (perhaps annually or once every few years) on cyber capabilities and resources dedicated to building cyber resilience
- Establishing an obligation to report cyber incidents to the prudential authority, perhaps with a materiality threshold for reporting incidents as soon as reasonable after they are detected
- An information collection plan that is applicable to all regulated entities of RBNZ
Keywords: Asia Pacific, New Zealand, Banking, Insurance, PMI, Guidance, Cyber Risk, Operational Risk, Cloud Computing, RBNZ
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