On February 16, 2017, BITS, the technology policy division of the Bank Policy Institute (BPI) — launched in 2018 following the merger of The Clearing House Association and the Financial Services Roundtable — submitted a comment letter in response to an Advanced Notice of Proposed Rulemaking (ANPR) issued by the Office of the Comptroller of the Currency (OCC), Federal Reserve, and the Federal Deposit Insurance Corporation (FDIC) on the topic of securing the financial sector from cybersecurity threats.

The letter makes several recommendations, including the adoption of a risk-based approach to cyber regulation and a need fora harmonization of existing frameworks.