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On April 20, 2020, the Financial Stability Board released a “consultative document” on Effective Practices for Cyber Incident Response and Recovery (the “Proposal”). The Proposal requests public comment on a “toolkit” of effective practices designed to assist financial institutions in cyber incident response and recovery activities. This Legal Update discusses the content and context of the Proposal and identifies how it would fit within the respective cybersecurity frameworks as well as key takeaways for financial institutions in the United States and in the Europe Union.
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