Emergency Justification Memo

DEPARTMENT OF THE TREASURY
WASHINGTON, D.C. 20220

TO:

Alex Goodenough, Office of Information and Regulatory Affairs
Digitally signed by
Ryan A. Law
Date: 2020.09.24
17:32:01 -04'00'

FROM:

Ryan Law
Deputy Assistant Secretary
Office of Privacy, Transparency, and Records

SUBJECT:

Justification for Emergency Processing: (Survey to Identify and Analyze the
Operational Dependencies of Financial Services Sector Critical Functions; OMB
Control Number 1505-0265)

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.