#
Pennsylvania lacks a payments-specific operational-resilience regime; DoBS points regulated entities to federal FFIEC/OCC/FDIC/Fed third-party risk guidance rather than issuing its own binding rules for payment firms. The Commonwealth's own binding cyber-incident law (the Breach of Personal Information Notification Act) is a general data-breach notification statute, not payments-sector operational resilience, and the newer PA Insurance Data Security Act is scoped to insurance licensees, not payment/money-transmission licensees.
Kept on Dataprotection.gi, not restated here: data and cloud switching obligations on service providers, including notice periods and charges. Open its jurisdiction pages on Dataprotection.gi →
Outlook
No legislative or regulatory move toward a dedicated state operational-resilience regime for payments was identified this cycle. This remains a standing structural gap in Pennsylvania's regulatory architecture worth monitoring should DoBS or the General Assembly move toward a state-level analogue to federal third-party risk-management expectations.
no periodic updates on record for this sub-brief
Sources and findings (4 unique sources · R-3/R-4)
- [W3-E1] T1 Derived: Confirmed in_forcehttps://www.legis.state.pa.us/WU01/LI/LI/US/HTM/2005/0/0094..HTM re-verified
<cite index="117-15,117-16">"Breach of the security of the system" is defined as the unauthorized access and acquisition of computerized data that materially compromises the security or confidentiality of personal information maintained by the entity and that causes or the entity reasonably believes has caused or will cause loss or injury to any resident of the Commonwealth.</cite>
<cite index="111-24">The Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency released a guide intended to assist community banks when developing and implementing their third-party risk management practices, which DoBS references directly rather than issuing its own binding standard.</cite>
- [W3-E3] T3 Derived: Probable in_forcehttps://www.lexology.com/library/detail.aspx?g=f7293fa7-0b88-432c-9f3a-9cf3ba1effed re-verified
<cite index="116-1,116-3">The generalized threats to banking that DOBS highlights in its letter and the newly created DOBS Cybersecurity Task Force are nothing new; the Task Force's website includes a litany of links and suggestions for regulated institutions, but all are pre-existing resources from other government agencies including FFIEC and the SEC.</cite>
- [W3-E4] T3 Derived: Probable in_forcehttps://www.righthandtechnologygroup.com/blog/compliance/pennsylvania-cybersecurity-regulations-2025-guide re-verified
<cite index="119-16,119-17">The Pennsylvania Insurance Data Security Act (PIDSA), signed into law as Act 2 of 2023, is scoped to insurance licensees and aligns with national cybersecurity standards, but does not extend to money-transmission or payments licensees, leaving a payments-specific operational-resilience gap at state level.</cite>