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OFR_2016_Financial-Stability-Report

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Figure 42. Banks that Include an Operational Risk<br />

or Cybersecurity Scenario in Dodd-Frank Act Stress<br />

Tests (number )<br />

Use of operational risk and cybersecurity scenarios is<br />

growing<br />

35<br />

30<br />

25<br />

20<br />

15<br />

10<br />

5<br />

0<br />

Banks with an operational or cybersecurity risk<br />

scenario<br />

Banks without an operational or cybersecurity risk<br />

scenario<br />

2013 2014 2015<br />

Note: Based on mid-cycle Dodd-Frank Act stress tests.<br />

Source: <strong>OFR</strong> analysis<br />

Figure 43. Mentions of “Cyber” in Large U.S.<br />

<strong>Financial</strong> Firms’ Form 10-Ks (number)<br />

Cyber risk is rising for systemically important U.S. financial<br />

firms and government-sponsored enterprises<br />

250<br />

200<br />

150<br />

100<br />

50<br />

0<br />

2013 2014 2015<br />

<strong>Financial</strong> Firms Increasingly See<br />

Cybersecurity Incidents as a Key Risk<br />

The threat of cyber incidents is widely recognized. Twothirds<br />

of global regulators and market experts surveyed<br />

in 2015 ranked the threat as a top financial stability<br />

risk. It placed second among all potential threats in<br />

the survey (see Worner, 2015). Similarly, half of bank<br />

chief risk officers and board members responding to a<br />

<strong>2016</strong> survey placed cybersecurity risk among the top<br />

issues requiring their attention (EY and IIF, <strong>2016</strong>).<br />

Increasingly, banks voluntarily include cyber risks and<br />

operational risks in the scenarios they submit to regulators<br />

as part of stress testing. Banks prepare these scenarios<br />

as part of mid-cycle stress tests required under<br />

the Dodd-Frank Act (see Figure 42).<br />

A number of U.S. financial firms reported cybersecurity<br />

as a key risk in 2015 10-K filings reviewed by<br />

the <strong>OFR</strong>. The analysis covered U.S. global systemically<br />

important banks, global systemically important<br />

insurers, central counterparties, and government-sponsored<br />

enterprises. Cybersecurity references in 2015<br />

Form 10-Ks were nearly double those in 2013 10-Ks<br />

(see Figure 43). These filings typically note that cyber<br />

incidents can come from a variety of bad actors,<br />

including organized crime, foreign governments, and<br />

insiders. They also note that cybersecurity incidents can<br />

arise when clients, third-party service providers, retail<br />

partners, or counterparties are targeted. Incidents can<br />

spread cyber risks to business partners of the firm.<br />

<strong>Financial</strong> firms are integrating cybersecurity preparedness<br />

into their risk management. They are investing<br />

in information security to address cybersecurity risks.<br />

About 40 percent of financial services firms in North<br />

America with more than $1 billion in revenue budgeted<br />

$10 million or more for information security, according<br />

to a <strong>2016</strong> survey (see PricewaterhouseCoopers, <strong>2016</strong>).<br />

That is more than most other industries (see Figure 44).<br />

Note: Form 10-Ks for firms in the sample grew on average 2.5<br />

percent in page count from 2013 to 2015.<br />

Sources: Securities and Exchange Commission Form 10-K, <strong>OFR</strong><br />

analysis<br />

42 <strong>2016</strong> | <strong>OFR</strong> <strong>Financial</strong> <strong>Stability</strong> <strong>Report</strong>

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