ITEM 1B – UNRESOLVED STAFF COMMENTS
+Added: Table of C ontents
ITEM 1C – CYBERSECURITY
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Any of these systems can be compromised, including through intentional acts or carelessness by employees, customers and other individuals who are authorized to use them, and by criminals, who often use sophisticated and constantly evolving set of software, tools and strategies to do so.
+Added: We expect the strength of these threats to continue to increase as criminals incorporate artificial intelligence tools into their strategies.
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, and any intrusion into our systems could result in material financial losses and operational problems.
See “Operational, Strategic and Reputational Risks.”
−Removed: Accordingly, we have developed an informational security program and devoted resources for assessing, identifying and managing risks associated with cybersecurity threats, including:
+Added: Accordingly, we have developed an information security program and devoted resources for assessing, identifying and managing risks associated with cybersecurity threats, including:
• established a dedicated internal cybersecurity team that is responsible for conducting regular assessments of our information systems, existing controls, vulnerabilities and potential improvements;
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Our management team is responsible for the day-to-day management of risks we face, including our Chief Information Security Officer.
−Removed: Our Chief Information Security Officer has 20 years of information technology and information security experience, and before joining our Company has held the positions of Chief Technology Officer and Director of IT and Information Security Officer at his prior places of employment.
+Added: Our Chief Information Security Officer has over 20 years of information technology and information security experience, and before joining our Company has held the positions of Chief Technology Officer and Director of IT and Information Security Officer at his prior places of employment.
+Added: Table of C ontents
In addition, our board of directors, as a whole and through its Risk Policy & Compliance Committee (the “Risk Committee”), is responsible for the oversight of risk management.
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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.