6 unchanged sentences
The Board of Directors has final responsibility, after consultation with management, for ensuring the Information Security Program aligns with the overall business strategy and provides oversight to protect the Company from ongoing and emerging threats, including those related to cybersecurity.
−Removed: The Information Security Program is overseen by the Company’s Chief Information Security Officer (CISO), who reports directly to the Chief Risk Officer.
−Removed: The CISO is responsible for the implementation, maintenance, and enforcement of the Information Security Program and related policies and standards.
+Added: The Information Security Program is overseen by the Company’s Information Security Officer ("ISO") , who reports directly to the Chief Risk Officer.
+Added: The ISO has held this position with the Company since May, 2024, and has worked at the Company in cybersecurity for almost 12 years and in the information technology industry for more than 16 years.
+Added: The Chief Risk Officer has held the position at the Company since October 2016, when he joined the Company from the FDIC where he was employed for 24 years and held multiple positions including Senior Risk Examiner for the Division of Risk Management Supervision and Acting Regional Manager for the Division of Insurance and Research.
+Added: During his tenure with the FDIC, the CRO served from time to time as the Examiner-in-Charge for Berkshire Bank and numerous other banks throughout New England.
+Added: The ISO is responsible for the implementation, maintenance, and enforcement of the Information Security Program and related policies and standards.
The program is evaluated and adjusted at least annually based on the results of testing, monitoring, and the adoption of best practices.
17 unchanged sentences
Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.