What changed in this filing

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Item 1B. Unresolved Staff Comments

2025-02-27 compared with 2024-02-23 · 26 added, 23 removed, 3 unchanged (94% of the section changed)

1 unchanged sentence

CYBERSECURITY

Busey relies extensively on various information systems and other electronic resources to operate our business.

In addition, nearly all of our customers, service providers and other business partners on whom we depend, including the providers of our online banking, mobile banking, and accounting systems, use their own information systems and electronic resources.

Any of these systems can be compromised, including through the employees, customers, and other individuals who are authorized to use them, and bad actors who use a sophisticated and constantly evolving set of software, tools, and strategies to do so.

Moreover, the nature of our business, as a financial services provider, and our relative size, make us and our business partners high-value targets for these bad actors to pursue.

For additional information see “ Item 1A.

Busey maintains a cyber security risk management program designed to prevent, detect, and respond to information security threats.

The program is designed to align with the Cyber Risk Institute’s Profile framework, which is based on the National Institute of Standards and Technology’s Cybersecurity Framework.

The program is led by Busey’s Chief Information Security Officer (“CISO”) .

Busey’s CISO has been in the role since September 2020 and has over 15 years of experience across external and internal audit, technology risk management, and cybersecurity matters, spanning various industries primarily within the financial services sector, but also including healthcare, technology, consumer products, and manufacturing for both regional and multinational corporations.

Busey’s cyber security risk management program is a key part of the Company’s overall risk management system, which is administered by the Chief Risk Officer.

Busey’s cyber security risk management program includes administrative, technical, and physical safeguards to help ensure the security and confidentiality of customer records and information.

Busey has long devoted significant resources to assessing, identifying, and managing risks associated with cybersecurity threats, including:

• Establishing an internal cybersecurity team that is responsible for conducting regular assessments of Busey’s information systems, existing controls, vulnerabilities, and potential improvements;

First Busey Corporation (BUSE) | 2024 — 46

• Employing continuous monitoring tools that can detect and help respond to cybersecurity threats in real-time;

• Performing due diligence with respect to third-party service providers , including their cybersecurity practices, and requiring contractual commitments from Busey’s service providers to take certain cybersecurity measures;

• Ongoing monitoring and assessment of third-party vendors' cybersecurity practices, including regular audits, compliance checks, and incident reporting requirements;

• Engaging third-party cybersecurity consultants, who conduct periodic penetration testing, vulnerability assessments, and other procedures to identify potential weaknesses in Busey’s systems and processes;

• Mandating periodic cybersecurity training for Busey’s workforce, which includes awareness programs on phishing, social engineering, and other common cyber threats;

• Implementing access control measures such as multi-factor authentication, role-based access controls, and regular access reviews to ensure that only authorized personnel have access to critical systems and data;

• Using data encryption for both data at rest and data in transit to protect sensitive information;

• Creating an incident response plan that outlines the steps to contain, mitigate, and remediate the impact of cybersecurity incidents, including communication protocols and post-incident analysis.

Busey’s security and privacy policies and procedures are in effect across all of its businesses and geographic locations.

Busey adheres to various regulatory requirements and standards, including the Gramm-Leach-Bliley Act to ensure compliance with data protection laws.

Additionally, Busey maintains cybersecurity insurance coverage to mitigate potential financial impacts from cyber incidents.

Busey’s board of directors , as a whole and through its Enterprise Risk Committee (the “Risk Committee”), is responsible for the oversight of risk management.

In that role, Busey’s board of directors and Risk Committee, with support from Busey’s cybersecurity advisors, are responsible for ensuring that the risk management processes developed and implemented by management are adequate and functioning as designed.

To carry out those duties, both the board of directors and the Risk Committee receive quarterly reports from Busey’s management team regarding cybersecurity risks, and Busey’s efforts to prevent, detect, mitigate, and remediate any cybersecurity incidents.

Busey’s historical data indicates that while Busey has encountered cybersecurity threats and incidents, none have materially affected the Company.

Still, Busey faces a number of cybersecurity risks in connection with its business, and it is possible that threats and incidents identified in the future could have a material adverse effect on Busey’s business strategy, results of operations, and financial condition.

For additional information on the risks that cybersecurity threats pose to Busey see “ Item 1A.

Risk Factors—Operational Risks .”

Accordingly, we have long devoted significant resources to assessing, identifying and managing risks associated with cybersecurity threats, including:

• an internal cybersecurity team that is responsible for conducting regular assessments of our information systems, existing controls, vulnerabilities and potential improvements;

• continuous monitoring tools that can detect and help respond to cybersecurity threats in real-time;

• performing due diligence with respect to our third-party service providers, including their cybersecurity practices, and requiring contractual commitments from our service providers to take certain cybersecurity measures;

• third-party cybersecurity consultants, who conduct periodic penetration testing, vulnerability assessments and other procedures to identify potential weaknesses in our systems and processes;

• periodic cybersecurity training for our workforce.

This information security program is a key part of our overall risk management system, which is administered by our Chief Risk Officer.

The program includes administrative, technical and physical safeguards to help ensure the security and confidentiality of customer records and information.

These security and privacy policies and procedures are in effect across all of our businesses and geographic locations.

We face a number of cybersecurity risks in connection with our business.

From time-to-time, we have identified cybersecurity threats and cybersecurity incidents that require us to make changes to our processes and to implement additional safeguards.

While none of these identified threats or incidents have materially affected us, it is possible that threats and incidents we identify in the future could have a material adverse effect on our business strategy, results of operations, and financial condition.

First Busey Corporation | 2023 — 49

Our management team is responsible for the day-to-day management of risks we face, including our Chief Information Security Officer (“CISO”).

Our CISO has been in the role since September 2020, and has 15 years of experience across external and internal audit, technology risk management, and cybersecurity spanning various industries primarily within the financial services sector, but also including healthcare, technology, consumer products, and manufacturing for both regional and multinational corporations.

In addition, our board of directors, as a whole and through its Enterprise Risk Committee (the “Risk Committee”), is responsible for the oversight of risk management.

In that role, our board of directors and Risk Committee, with support from Busey’s cybersecurity advisors, are responsible for ensuring that the risk management processes designed and implemented by management are adequate and functioning as designed.

To carry out those duties, both our board of directors and the Risk Committee receive quarterly reports from our management team regarding cybersecurity risks, and Busey’s efforts to prevent, detect, mitigate, and remediate any cybersecurity incidents.

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.

What changed 10-K

Item 1B. Unresolved Staff Comments