Cyber Security: OSFI Issues Self-Assessment Questionnaire

For financial and sometimes political reasons financial institutions are appealing targets for cyber attackers. Earlier this year TD Canada Trust was hit by a cyber attack¹ whereby one or more hackers used a brute force "denial of service" attack to disable the bank's website and mobile application. This attack was reminiscent of the September 2012 attack in the U.S.² in which the websites of Bank of America, JPMorgan Chase, Wells Fargo, U.S. Bank and PNC Bank were all subject to similar attacks that slowed down website operations and caused many bank sites to be inoperative for a significant portion of their customers. Mindful of this very real threat and the need to manage risk, on October 28, 2013, the Office of the Superintendent of Financial Institutions ("OSFI") released a memorandum to federally regulated financial institutions ("FRFIs") discussing the measures that FRFIs should be taking to prevent, manage and remediate cyber attacks. The memorandum states that