2 unchanged sentences
Risk Management and Strategy Overview
−Removed: connection with the services we provide.
−Removed: The Company realizes that cyber incidents can have financial, reputational,
−Removed: and operational impacts that can
−Removed: significantly adversely affect our customers, capital, and
−Removed: Therefore, we integrate
−Removed: cybersecurity processes throughout the Company as part of our enterprise-wide governance process.
+Added: Customers depend
+Added: nonpublic personal
+Added: Company understands
+Added: incidents can
+Added: have financial,
+Added: reputational, legal,
+Added: operational impacts
+Added: adversely affect
+Added: our customers,
+Added: cybersecurity
+Added: processes throughout the
+Added: Company as part of
+Added: our enterprise-wide governance
Regulatory agencies
1 unchanged sentence
cybersecurity
−Removed: framework offers a set of guidelines
−Removed: and best practices to help
−Removed: financial institutions manage and mitigate cybersecurity risks
−Removed: It focuses on ensuring the confidentiality,
+Added: expectations set forth
+Added: by the Federal
+Added: Financial Institutions
+Added: Examination Council
+Added: FFIEC framework
+Added: cybersecurity
+Added: focuses on ensuring the confidentiality,
integrity, and availability
4 unchanged sentences
Compliance Department
−Removed: provides expert
−Removed: cybersecurity and
−Removed: presents periodic
−Removed: Risk Committee of our Board of Directors.
+Added: expert counsel
+Added: of cybersecurity
+Added: periodic reports
+Added: Committee of our Board of Directors.
program, periodic
7 unchanged sentences
of controls currently
−Removed: Company utilizes
−Removed: Standards and
−Removed: (“NIST”) Framework
−Removed: Cybersecurity
+Added: The Company utilizes the National Institute of Standards and
+Added: (“NIST”) Framework and the Cyber Risk
+Added: Institute Framework (“CRI
+Added: Framework”) to help
+Added: management identify its
+Added: risks and determine
+Added: the Company’s
cybersecurity
−Removed: Company’s cybersecurity posture.
implementation
−Removed: of rigorous procedures
−Removed: and controls, augmented
−Removed: training initiatives for both management and staff, the institution cultivates a safe cybersecurity environment.
−Removed: This approach
+Added: and controls,
+Added: both management and
+Added: staff, the institution
+Added: cultivates a safe
+Added: cybersecurity environment.
+Added: approach encompasses diverse
methodologies
defense-in-depth
−Removed: fortifying the institutions cybersecurity controls and fostering
−Removed: a resilient operational framework.
+Added: institutions’
+Added: cybersecurity controls and fostering a resilient operational
Assessment and Response to Cybersecurity Threats
13 unchanged sentences
capabilities.
−Removed: The Company realizes that it faces a variety of risks from cyber-attacks involving destructive malware, including
−Removed: capital, operational,
−Removed: and reputation
−Removed: disruption of
−Removed: risk management
−Removed: processes, and
−Removed: business continuity
−Removed: planning address
−Removed: these risks by:
+Added: The Company recognizes that it faces a variety of risks from cyber-attacks involving destructive malware, including
+Added: liquidity, capital, operational, and
+Added: reputation risks, due
+Added: to events such
+Added: as fraud, data
+Added: loss, and disruption
+Added: management processes,
+Added: continuity planning
+Added: address these risks by:
comprehensive
information/cybersecurity
−Removed: Securely configuring systems and services to mitigate the impact of cyberattacks.
+Added: Securely configuring systems and services to mitigate the impact of cyber-threats.
This includes measures such as
−Removed: segmentation,
+Added: logical network segmentation, backups, maintaining an inventory
+Added: of authorized devices and software, and physical
configuration
−Removed: environment by removing or disabling unused applications, functions,
−Removed: or components.
+Added: removing or disabling unused applications, functions, or components.
Implementing and testing
9 unchanged sentences
senior management
+Added: taken to remediate findings.
Performing security
7 unchanged sentences
systems, antivirus protection,
−Removed: properly configured firewall
−Removed: monitored to identify,
−Removed: prevent, and contain
−Removed: attack attempts from
+Added: properly configured
+Added: are monitored
+Added: from all sources.
USCB Financial Holdings, Inc.
8 unchanged sentences
cyber-attacks
−Removed: impacting the Company or its critical service providers.
+Added: impacting the Company and/or its critical service providers.
Conducting ongoing
16 unchanged sentences
committees and
−Removed: review reports submitted
−Removed: RMCD detailing the
−Removed: Company’s inherent and
−Removed: cybersecurity risk, program sophistication level, and high-risk
−Removed: threats identified in the cybersecurity risk assessment.
+Added: (“ARC”) review
+Added: reports submitted
+Added: RMCD detailing
+Added: cybersecurity
+Added: sophistication
+Added: cybersecurity risk assessment.
effectiveness,
−Removed: cybersecurity controls and procedures.
−Removed: The Board receives regular
−Removed: on cybersecurity risk assessment
+Added: cybersecurity controls
+Added: and procedures.
+Added: receives regular
+Added: on cybersecurity
+Added: risk assessment
coordination, assignment of responsibility,
1 unchanged sentence
security program.
−Removed: Annually, or as required, the RMCD
−Removed: provides a comprehensive report
−Removed: to the Board or
−Removed: a designated committee regarding
+Added: comprehensive
cybersecurity
Cybersecurity
−Removed: Assessment, discussion
−Removed: of significant
−Removed: program matters
−Removed: risk assessment,
−Removed: risk management
+Added: discussion of
+Added: significant program
+Added: assessment, risk
+Added: management decisions,
monitoring of
−Removed: service provider
−Removed: compliance, results
−Removed: controls testing,
−Removed: security breaches
−Removed: or violations,
−Removed: responses, and recommendations for program enhancements.
+Added: service provider compliance, results of key controls testing, security breaches
+Added: or violations, management's responses, and
+Added: recommendations for program enhancements.
Engagement with Third Party Vendors
−Removed: The engagement
−Removed: of third-party
−Removed: involves potential
−Removed: strategic, reputational,
−Removed: considerations.
−Removed: specifically as
−Removed: to compliance
−Removed: requirements of the
−Removed: Gramm Leach Bliley
−Removed: regulation and applicable
−Removed: Laws and Regulations.
−Removed: developed general guidelines for
−Removed: the identification, risk assessment, monitoring
−Removed: and management of
−Removed: associated to the engagement of third-party providers
−Removed: officers, finance
−Removed: internal auditors,
−Removed: identify potential
−Removed: engagement as
−Removed: identify performance
−Removed: criteria, internal
−Removed: controls, reporting
−Removed: any contractual
−Removed: that should be implemented for the ongoing assessment and
−Removed: control of risks that derive from the third-party
+Added: The engagement of critical third-party providers introduces a range of
+Added: potential risks that can affect the Bank’s strategic
+Added: direction, reputation, daily
+Added: operations, transaction integrity,
+Added: credit exposures, financial
+Added: technological environment,
+Added: and compliance posture.
+Added: Providers whose services include the transmission, storage, or processing
+Added: of non-public personal
+Added: present heightened
+Added: compliance risks,
+Added: applicable Privacy Laws and Regulations.
+Added: identification,
+Added: management of risks related
+Added: to the engagement of
+Added: third-party providers or vendors.
+Added: This framework ensures that risks
+Added: addressed proactively and in accordance with regulatory
+Added: expectations.
+Added: Risk assessment for
+Added: critical providers may
+Added: require the involvement
+Added: of specialized personnel,
+Added: including the compliance
+Added: officer, technology officers, finance officers,
+Added: internal auditors, and
+Added: legal counsel.
+Added: participation is essential
+Added: for identifying
+Added: potential risks arising
+Added: from third-party relationships,
+Added: defining performance criteria,
+Added: establishing internal controls,
+Added: reporting requirements, and ensuring
+Added: contractual obligations are in
+Added: place for ongoing risk assessment
+Added: and mitigation.
+Added: collaborative approach helps maintain the integrity and security of the
+Added: Bank’s operations while meeting regulatory and legal
Compliance with Regulatory Standards
−Removed: Annual testing or
−Removed: more frequently if
−Removed: deemed necessary
−Removed: of cybersecurity controls
−Removed: and procedures will
−Removed: ensure compliance.
−Removed: of identified
−Removed: deficiencies or
−Removed: vulnerabilities,
+Added: As noted above, annual testing, or more frequently
+Added: if deemed necessary,
+Added: of cybersecurity controls and procedures
+Added: identified deficiencies
+Added: or vulnerabilities,
remedial action
−Removed: be implemented
−Removed: rectify issues or establish mitigating
−Removed: Any exceptions deemed significant will
−Removed: be promptly reported, with remediation
−Removed: efforts prioritized.
+Added: implemented to rectify issues or establish mitigating controls.
+Added: Any exceptions
+Added: deemed significant will be promptly reported,
+Added: with remediation efforts prioritized.
comprehensive
2 unchanged sentences
program matters.
+Added: USCB Financial Holdings, Inc.
As of the end of
7 unchanged sentences
continues to monitor developments and vendor communications.
−Removed: USCB Financial Holdings, Inc.
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.