8 unchanged sentences
That individual also reports regularly to our Board of Directors, oversees certain policies and procedures that are intended to guard against, detect, and respond to potential breaches of our IT systems.
−Removed: Although the SEC’s new cybersecurity reporting requirements do not require us to file a Form 8-K announcing the occurrence of material cybersecurity incidents, that obligation will apply to the Company with respect to material incidents discovered after June 15, 2024, and we are adapting our disclosure procedures to assure the timely compliance with the Company’s obligations under Item 1.05 of Form 8-K once that requirement becomes applicable to the Company.
−Removed: In the meantime, we continue to evaluate and monitor cybersecurity risks to assess whether any detected incident would be material to investors and, in such an event, we would make a timely report of a material incident under Item 7.01 or Item 8.01 of Form 8-K.
Managing Material Risks & Integrated Overall Risk Management
11 unchanged sentences
The Board provides clear guidance to regarding strategic goals and acceptable risk appetite with respect to third-party relationships.
−Removed: The Board reviews this policy on at least an annual basis to assure that we implement procedures and practices have been established by management.
+Added: The Board reviews this policy on at least an annual basis to assure that we implement
+Added: procedures and practices have been established by management.
Our chief risk officer is responsible for development and implementation of third-party risk management policies, procedures, and practices, commensurate with the Company’s strategic goals, risk appetite and the level of risk and complexity of its third-party relationships.
26 unchanged sentences
In addition to regular meetings, the BRCC, the ISO, Chief Risk Officer, Chief Information Officer, and Chief Executive Officer maintain an ongoing dialogue regarding emerging or potential cybersecurity risks that we face, particularly as a financial institution.
−Removed: The Company’s Management Risk and Compliance Committee also reports directly to the BRCC regarding our risk management initiatives.
+Added: T he Company’s Management Risk and Compliance Committee also reports directly to the BRCC regarding our risk management initiatives.
The BRCC also receives quarterly reports from the Executive IT Committee and IT department in order to say informed on all aspects of cybersecurity risk affecting the Company.
20 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.