Banking and Finance Law Daily Wrap Up, FINANCIAL TECHNOLOGY—Report offers guidance for banks on dealing with disruptions, (Aug 27, 2026)

By Nora Macaluso

The document, from the ABA, FS-ISAC, and the Treasury’s cybersecurity office, has advice for banks to follow before, during, and after a significant event.

A new document provides U.S. financial institutions with guidance on how to prepare, handle, and recover from “significant” disruptions such as cyberattacks, natural disasters, and third-party issues. The American Bankers Association (ABA), the Financial Services Information Sharing and Analysis Center (FS-ISAC), and the U.S. Department of the Treasury’s Office of Cybersecurity and Critical Infrastructure Protection (OCCIP) developed the plan, which they said aligns with guidance from FS-ISAC, the Financial Services Sector Coordinating Council (FSSCC), the Financial and Banking Information Infrastructure Committee (FBIIC), and federal and state regulators.

The recommendations are aimed at individuals and teams responsible for developing incident-response plans and responding to incidents.

Resilience requires strong relationships with federal and local agencies and industry partners, including the Cybersecurity and Infrastructure Security Agency (CISA) Cyber Security Advisors (CSA), CISA Protective Security Advisors (PSA), Federal Bureau of Investigation (FBI) InfraGard, Domestic Security Alliance Council (DSAC), FS-ISAC, and regional coalitions, the document says. It includes a list of agencies and website links.

The guide discusses resources banks can use to plan for and strengthen incident response. Thes include tools from CISA, the National Institutes of Standards and Technology (NIST), Federal Financial Institutions Examination Council (FFIEC), Federal Emergency Management Agency (FEMA), and other organizations.

Banks can register for government services including the Department of Homeland Security’s Homeland Security Information Network (HSIN), CISA’s no-cost cyber hygiene services, and priority telecommunications programs, and participate in exercises offered by FS-ISAC, the Global Resilience Federation, FEMA, and CISA to identify gaps and validate plans.

During an event, banks need to be in touch with regulators, government agencies, and trade associations, and effectively communicate with employees, customers, and others, the guide says. Notification practices will be different depending on the nature of the event.

“Institutions should be mindful of other considerations including the need to engage legal counsel, collect appropriate information for investigators, and prepare to comply with incident notification and reporting requirements,” the document says. “Firms should also note that incidents may require firms to notify or coordinate with entities outside of U.S.”

The guide also outlines actions to comply with incident notification and reporting requirements after an event, including requirements for publicly traded institutions that must follow Securities and Exchange Commission (SEC) rules. Financial institutions must also file suspicious activity reports (SARs).

After an event, organizations should follow up with reviews and evaluations of response effectiveness, as well as update risk assessments and continuity plans and adjust budgets and strategies, the report says.

“Resilience is built before the crisis begins,” John Carlson, SVP for cybersecurity regulation and resilience at ABA, said in an article in the ABA Banking Journal. “For financial institutions, that means establishing trusted relationships, testing response plans and ensuring decision-makers know whom to call and what programs and support they can leverage to strengthen their response.”

Companies: American Bankers Association; Financial Services Information Sharing and Analysis Center

RegulatoryActivity: BankingOperations CyberPrivacyFeed DataPrivacy DataSecurity FinTech IdentityTheft Privacy