Annual report [Section 13 and 15(d), not S-K Item 405]

Cybersecurity Risk Management and Strategy Disclosure

v3.25.4
Cybersecurity Risk Management and Strategy Disclosure
12 Months Ended
Dec. 31, 2025
Cybersecurity Risk Management, Strategy, and Governance [Line Items]  
Cybersecurity Risk Management Processes For Assessing Identifying And Managing Threats [Text Block]
Risk Management
 
and Strategy
Our enterprise risk management program is designed to identify,
 
assess, and mitigate risks across various aspects of our
Company, including
 
financial, operational, market, regulatory,
 
technology, legal, and reputational.
 
Cybersecurity is a critical risk
area given the increasing reliance on technology and potential of cyber
 
risk threats.
 
Our Chief Information Security Officer
(“CISO”) reports to the CCB President who provides oversight of the information
 
security program and its activities, along with
our management-level Enterprise Risk Oversight Committee
 
(“ROC”) and our Board of Directors.
Our objective for managing cybersecurity risk is to avoid or minimize the impacts
 
of external threat events or other efforts to
penetrate, disrupt or misuse systems or information.
 
Our cybersecurity risk management program is designed around the National
Institute of Standards and Technology
 
(“NIST”) Cybersecurity Framework, regulatory guidance, and other industry
 
standards,
although we cannot guarantee that we meet all technical specifications, or
 
requirements under NIST.
 
Our CISO and Information
Security Officers (“ISOs”) along with key members of
 
the information security team collaborate with peer banks, industry groups,
and policymakers to discuss cybersecurity trends and issues and identify best practices.
 
Our information security program,
including our cyber risk management policies and procedures and
 
our incident response program, are periodically reviewed by
 
the
CISO with the goal of addressing changing threats and conditions.
 
The parts of our information security program relating to cybersecurity are built
 
on a multi-layered and integrated defense model
and include the following processes:
Risk-based controls for information systems and information
 
on our networks:
 
We maintain risk
 
management
processes designed to identify,
 
assess, and manage cybersecurity risks associated with external service
 
providers and the
services we provide to our clients. We
 
leverage people, processes, and technology as part of our efforts
 
to manage and
maintain cybersecurity controls. We
 
also employ a variety of preventative and detective tools designed
 
to monitor, block,
and provide alerts regarding suspicious activity,
 
as well as to report on suspected advanced persistent threats. We
 
seek to
maintain a risk management infrastructure that implements physical, administrative
 
and technical controls that are
designed, based on risk, to protect our information systems and the information
 
stored on our networks, including personal
information, intellectual property and proprietary information of our
 
Company and our clients.
Incident response program:
We have an
 
incident response program and dedicated teams to respond to cybersecurity
incidents. When a cybersecurity incident occurs, we have cross-functional
 
teams that are responsible for leading the initial
assessment of priority and severity and communicating potentially material
 
cybersecurity incidents to the appropriate
members of management and the Board of Directors.
Training and testing:
We have
 
established processes and systems designed to mitigate cybersecurity risk, including
regular education and training for associates, preparedness simulations and
 
tabletop exercises, and recovery and resilience
tests. We also monitor
 
our email gateways for malicious phishing email campaigns and monitor remote
 
connections.
Internal and external risk assessments:
 
We engage
 
in ongoing assessments of our infrastructure, software systems,
 
and
network architecture using internal experts and
third-party
 
specialists, including to identify material risks from
cybersecurity threats.
 
Our internal auditor and other independent external partners will periodically
review
 
our processes,
systems, and controls, including with respect to our information security program,
 
to assess their design and operating
effectiveness and make recommendations to strengthen
 
our risk management processes.
 
Notwithstanding our defensive measures and processes, threats posed
 
by cyberattacks are severe.
 
Our internal systems,
processes, and controls are designed to mitigate loss from cyber-attacks
 
and, while we have experienced cybersecurity incidents
in the past, to date, risks from cybersecurity threats have
not materially
 
affected, and are not reasonably likely to materially affect,
the Company, including
 
its business strategy, results of
 
operations or financial condition. Despite the Company’s
 
efforts, there
can be no assurance that its cybersecurity risk management processes and
 
measures described will be fully implemented,
complied with, or effective in protecting its systems and information.
 
The company faces risks from certain cybersecurity threats
that, if realized, are reasonably likely to materially affect
 
its business strategy, results of
 
operations or financial condition.
 
For
further discussion of risks from cybersecurity threats, see Item 1A. Risk Factors under
 
the section captioned “Cybersecurity
incidents, including security breaches and failures of our information
 
systems could significantly disrupt our business, result in
the unintended disclosure or misuse of confidential or proprietary information,
 
damage our reputation, increase our costs, and
cause losses.”
Cybersecurity Risk Management Processes Integrated [Flag] true
Cybersecurity Risk Management Processes Integrated [Text Block]
Our enterprise risk management program is designed to identify,
 
assess, and mitigate risks across various aspects of our
Company, including
 
financial, operational, market, regulatory,
 
technology, legal, and reputational.
 
Cybersecurity is a critical risk
area given the increasing reliance on technology and potential of cyber
 
risk threats.
Cybersecurity Risk Management Third Party Engaged [Flag] true
Cybersecurity Risk Third Party Oversight And Identification Processes [Flag] true
Cybersecurity Risk Materially Affected Or Reasonably Likely To Materially Affect Registrant [Flag] false
Cybersecurity Risk Materially Affected Or Reasonably Likely To Materially Affect Registrant [Text Block]
Notwithstanding our defensive measures and processes, threats posed
 
by cyberattacks are severe.
 
Our internal systems,
processes, and controls are designed to mitigate loss from cyber-attacks
 
and, while we have experienced cybersecurity incidents
in the past, to date, risks from cybersecurity threats have
not materially
 
affected, and are not reasonably likely to materially affect,
the Company, including
 
its business strategy, results of
 
operations or financial condition. Despite the Company’s
 
efforts, there
can be no assurance that its cybersecurity risk management processes and
 
measures described will be fully implemented,
complied with, or effective in protecting its systems and information.
 
The company faces risks from certain cybersecurity threats
that, if realized, are reasonably likely to materially affect
 
its business strategy, results of
 
operations or financial condition.
Cybersecurity Risk Board Of Directors Oversight [Text Block]
Board Oversight of Cybersecurity
The Board of Directors oversee cybersecurity risk and the information security
 
program which includes overseeing management’s
actions to identify, assess, mitigate
 
and remediate or prevent material cybersecurity risks. The CISO provides
 
reports to the Board
of Directors annually on the status of the information security program and risks, notable
 
threats and incidents, and other
developments related to cybersecurity of the information security program
 
.
 
An appropriate committee of the Board of Directors
may also receive from the CISO periodic reports on these activities, as well as the status of
 
any incident response and remediation
efforts the Company may undertake.
Cybersecurity Risk Board Committee Or Subcommittee Responsible For Oversight [Text Block]
Our
CISO
 
is responsible for managing our Corporate Security Department
 
and overseeing our information security program,
including cybersecurity risks.
Cybersecurity Risk Process For Informing Board Committee Or Subcommittee Responsible For Oversight [Text Block]
On a quarterly basis, and as needed, the CISO reports the status of the information
security program, notable threats or incidents, and other developments related
 
to information security and cybersecurity risks to
our ROC.
Cybersecurity Risk Role Of Management [Text Block]
The responsibilities of this department include cybersecurity risk assessment, defense
 
operations,
incident response, vulnerability assessment, threat intelligence, third-party
 
risk management, information governance risk and
compliance and business resilience. The foregoing responsibilities are covered
 
on a day-to-day basis with oversight and guidance
provided by our CISO, the ISOs and key members of the information security
 
team.
The department, as a whole, consists of
information security professionals with varying degrees of education and
 
experience. Associates within the department are
generally subject to professional education and certification requirements.
 
In particular, our CISO has over 15 years of substantial
relevant expertise and formal training in the areas of information security and cybersecurity
 
risk management and also serves on
several advisory boards and committees within the financial sector.
Our CISO regularly
reports
 
on the status of the information
security program to the CCB President.
On a quarterly basis, and as needed, the CISO reports the status of the information
security program, notable threats or incidents, and other developments related
 
to information security and cybersecurity risks to
our ROC.
 
Board Oversight of Cybersecurity
The Board of Directors oversee cybersecurity risk and the information security
 
program which includes overseeing management’s
actions to identify, assess, mitigate
 
and remediate or prevent material cybersecurity risks. The CISO provides
 
reports to the Board
of Directors annually on the status of the information security program and risks, notable
 
threats and incidents, and other
developments related to cybersecurity of the information security program
 
.
 
An appropriate committee of the Board of Directors
may also receive from the CISO periodic reports on these activities, as well as the status of
 
any incident response and remediation
efforts the Company may undertake.
Cybersecurity Risk Management Positions Or Committees Responsible [Flag] true
Cybersecurity Risk Management Positions Or Committees Responsible [Text Block]
Our
CISO
 
is responsible for managing our Corporate Security Department
 
and overseeing our information security program,
including cybersecurity risks.
Cybersecurity Risk Management Expertise Of Management Responsible [Text Block]
The department, as a whole, consists of
information security professionals with varying degrees of education and
 
experience. Associates within the department are
generally subject to professional education and certification requirements.
 
In particular, our CISO has over 15 years of substantial
relevant expertise and formal training in the areas of information security and cybersecurity
 
risk management and also serves on
several advisory boards and committees within the financial sector.
Cybersecurity Risk Process For Informing Management Or Committees Responsible [Text Block]
Our CISO regularly
reports
 
on the status of the information
security program to the CCB President.
On a quarterly basis, and as needed, the CISO reports the status of the information
security program, notable threats or incidents, and other developments related
 
to information security and cybersecurity risks to
our ROC.
Cybersecurity Risk Management Positions Or Committees Responsible Report To Board [Flag] true