Survey to Identify and Analyze the Operations Dependencies of Financial Services Sector Critical Functions

Forms and Documents

Document Name	Status
1505-0265 - OCCIP - Emergency Justification Memo to OMB_FINAL.pdf Supplementary Document	2020-09-25
1505-0265_OCCIP Survey SS-B_Final.docx Supporting Statement B	2020-09-25
1505-0265_OCCIP Survey SS-A_Final.docx Supporting Statement A	2020-09-25

IC Document Collections

IC ID	Document Title	Status
243789	Financial Services Sector Critical Functions Survey Other-null	New

ICR Details

OMB Control No: 1505-0265	ICR Reference No: 202009-1505-004
Status: Active	Previous ICR Reference No:
Agency/Subagency: TREAS/DO	Agency Tracking No:
Title: Survey to Identify and Analyze the Operations Dependencies of Financial Services Sector Critical Functions
Type of Information Collection: New collection (Request for a new OMB Control Number)	Common Form ICR:  No
Type of Review Request: Emergency	Approval Requested By: 09/28/2020
OIRA Conclusion Action: Approved without change	Conclusion Date: 09/29/2020
	Date Received in OIRA: 09/28/2020
Terms of Clearance:

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	03/31/2021	6 Months From Approved
Responses	50	0	0
Time Burden (Hours)	3,000	0	0
Cost Burden (Dollars)	0	0	0

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Abstract: Pursuant to Executive Order 13636 (EO13636) Improving Critical Infrastructure Cybersecurity and Presidential Policy Directive 21 (PPD 21) Critical Infrastructure Security and Resilience, Treasury serves as the Sector-Specific Agency (SSA) for the financial services sector. Within Treasury, the Office of Cybersecurity and Critical Infrastructure Protection (OCCIP) executes the Department’s SSA responsibilities as part of its mission to enhance the security and resilience of the financial services sector’s critical infrastructure. Further, OCCIP supports the implementation of the National Cyber Strategy as it pertains to financial services cybersecurity. To enable Treasury to fulfill its SSA duties, and given increased cybersecurity risks related to COVID-19 pandemic response, OCCIP seeks to collect and analyze information on cyber threats and vulnerabilities to better understand the cybersecurity risk to the U.S. financial services sector operations and critical infrastructure. OCCIP intends to solicit this information from approximately 50 respondents representing the largest systemically important financial institutions and financial market utilities, which collectively form the backbone of U.S. financial service critical infrastructure. OCCIP is requesting information related to each respondent’s critical functions and processes, including various business lines and intrasector relationships. This information collection will support OCCIP’s efforts to enhance the security and resilience of the financial services sector, and to work collaboratively with industry and interagency partners to mitigate cybersecurity risks that could impact financial services sector operations.

Emergency Justfication: The Department of Treasury (Treasury) is requesting emergency processing of a new collection (OMB 1505-0265) to survey financial institutions to identify security vulnerabilities. Treasury is requesting emergency approval for this information collection to support incident response and continuity of the economy planning in light of the COVID-19 pandemic. Following the declaration of a public health emergency in numerous jurisdictions (including, but not limited to, the New York metropolitan area), the U.S. financial services sector workforce moved to telework to accommodate shelter-in-place orders. This shift to remote operations has introduced new cybersecurity risks and vulnerabilities to financial services critical infrastructure, with the potential to disrupt critical functions and processes that enable the U.S. financial system. Treasury is seeking information from financial services firms regarding their networks, systems, and data to better understand how these firms are interconnected and the vulnerabilities that arise from these connections that, if exploited by a cyber threat actor, could negatively impact the operations of the U.S. financial services sector and the broader U.S. economy. In particular, Treasury has observed increased reports of ransomware attacks against financial services firms and service providers. Therefore, it is critical that Treasury is able to solicit and collect this information in a timely fashion to reduce growing cybersecurity risks to the financial services sector as it maintains remote operations due to COVID-19. Due to the unprecedented COVID-19 emergency situation, Treasury is planning to begin administering these surveys on September 30, 2020. In order to meet this tight deadline, Treasury would like to request a waiver of the requirement to publish a notice seeking public comments during the Office of Management and Budget (OMB) review period and requests OMB approval by September 28, 2020.

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Authorizing Statute(s): EO: EO 13636 Name/Subject of EO: Improving Critical Infrastructure Cybersecurity
  

Citations for New Statutory Requirements: None

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Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
	Not associated with rulemaking

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Federal Register Notices & Comments

Did the Agency receive public comments on this ICR? No

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Number of Information Collection (IC) in this ICR: 1

IC Title	Form No.	Form Name
Financial Services Sector Critical Functions Survey

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ICR Summary of Burden

	Total Approved	Previously Approved	Change Due to New Statute	Change Due to Agency Discretion	Change Due to Adjustment in Estimate	Change Due to Potential Violation of the PRA
Annual Number of Responses	50	0	0	50	0	0
Annual Time Burden (Hours)	3,000	0	0	3,000	0	0
Annual Cost Burden (Dollars)	0	0	0	0	0	0

Burden increases because of Program Change due to Agency Discretion: Yes

Burden Increase Due to: Miscellaneous Actions

Burden decreases because of Program Change due to Agency Discretion: No

Burden Reduction Due to:

Short Statement: This is a new collection.

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Annual Cost to Federal Government: $1,091,000

Does this IC contain surveys, censuses, or employ statistical methods? Yes Part B of Supporting Statement

Does this ICR request any personally identifiable information (see OMB Circular No. A-130 for an explanation of this term)? Please consult with your agency's privacy program when making this determination.     No

Does this ICR include a form that requires a Privacy Act Statement (see 5 U.S.C. §552a(e)(3))? Please consult with your agency's privacy program when making this determination.     No

Is this ICR related to the Affordable Care Act [Pub. L. 111-148 & 111-152]? No

Is this ICR related to the Dodd-Frank Wall Street Reform and Consumer Protection Act, [Pub. L. 111-203]? No

Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)? No

Is this ICR related to the Pandemic Response? Yes

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Common Form ICR:  No

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On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).

The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:

(a) It is necessary for the proper performance of agency functions;

(b) It avoids unnecessary duplication;

(c) It reduces burden on small entities;

(d) It uses plain, coherent, and unambiguous language that is understandable to respondents;

(e) Its implementation will be consistent and compatible with current reporting and recordkeeping practices;

(f) It indicates the retention periods for recordkeeping requirements;

(g) It informs respondents of the information called for under 5 CFR 1320.8 (b)(3) about:

(i) Why the information is being collected;

(ii) Use of information;

(iii) Burden estimate;

(iv) Nature of response (voluntary, required for a benefit, or mandatory);

(v) Nature and extent of confidentiality; and

(vi) Need to display currently valid OMB control number;

(h) It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to be collected.

(i) It uses effective and efficient statistical survey methodology (if applicable); and

(j) It makes appropriate use of information technology.

If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.

Certification Date: 09/28/2020

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