On January 18, the U.S. Office of the Comptroller of the Currency ("OCC") released its Semiannual Risk Perspective for Fall 2017 and identified several key data and privacy risk areas facing banks and other financial institutions today. The OCC found that the severity of cyber threats has increased and that criminals continue to target personal information in aggressive, innovative new ways. The OCC also warned that institutions' over-reliance on a few third-party servicers creates the risk of "concentrated points of failure" should one of these servicers suffer a data breach or other cyberattack.

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