6 unchanged sentences
Cybersecurity risk is assessed and managed primarily through our operations, risk management, and audit teams and is overseen by our Board of Directors.
−Removed: The Bank’s Information Security Officer (or ISO), who reports to our Chief Compliance & Risk Officer, is directly responsible for assessing and managing cybersecurity risks pursuant to the Company’s Information Security Program, which is approved by our Board of Directors periodically.
+Added: The Bank’s Information Security Officer (“ISO”) , who reports to our Chief Compliance & Risk Officer, is directly responsible for assessing and managing cybersecurity risks pursuant to the Company’s Information Security Program, which is approved by our Board of Directors periodically.
The current ISO has more than 5 years of cybersecurity experience and holds multiple industry certifications.
2 unchanged sentences
The ISO also reports any matter relating to cybersecurity incident responses and control deficiencies to our Board of Directors and its Audit Committee, respectively.
−Removed: The cybersecurity department of the Bank’s Information Technology (or IT) department is responsible for the day-to-day operations of our cybersecurity controls and defenses.
−Removed: The department is managed by the Bank’s Director of Information Systems and Security, who reports to the Bank’s Chief Technology Officer.
−Removed: The current Director of Information Systems and Security has more than 24 years of technology and cybersecurity experience.
+Added: The cybersecurity department of the Bank’s Information Technology (“IT”) department is responsible for the day-to-day operations of our cybersecurity controls and defenses.
+Added: The department is managed by the Bank’s Director of Information Systems and Security, who reports to the Bank’s Chief Technology Officer The current Director of Information Systems and Security has more than 24 years of technology and cybersecurity experience.
Our Chief Technology Officer periodically reports information about the Company’s cybersecurity risks and operational developments to our Board of Directors.
8 unchanged sentences
We also engage multiple independent third parties or cyber experts to detect and defend against cybersecurity threats and to assess information security programs and practices including penetration testing.
−Removed: Additionally, we participate in various cybersecurity industry forums and have access to law enforcement analyses regarding current threats.
+Added: Additionally,
+Added: we participate in various cybersecurity industry forums and have access to law enforcement analyses regarding current threats.
The ISO, along with the Bank’s Third-Party Oversight Committee, evaluates cybersecurity risks and information systems of third parties whose information systems support important Company operations or with whom the Company has significant business relationships at onboarding, on an ongoing basis and upon termination of the business relationship.
8 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.