US-PA v2.0 Sign in

US-PA (US-PA) · Module W3 · Derived Confidence: Probable

US-PA: Operational Resilience & Critical Infrastructure

#

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.

Open gap — wpm-int-1No delta this cycle located for W3 Operational Resilience & Critical Infrastructure.no under-indexing note recorded
Standing sub-brief · as of 5 July 2026133 words · last cycle 2026-07-05

Operational Resilience & Critical Infrastructure

Pennsylvania has no payments-specific state operational-resilience regime. Payment/money-transmission licensees; DoBS refers regulated entities to federal FFIEC/OCC/FDIC/Fed third-party risk guidance rather than issuing a binding state-level operational-resilience rule of its own. The one operational-resilience-adjacent state statute identified, the Insurance Data Security Act (Act 2 of 2023), is scoped to insurance licensees only and does not reach payment or money-transmission licensees. This leaves Pennsylvania payments operators reliant entirely on federal supervisory guidance for operational-resilience expectations, a materially lighter-touch position than DORA-style regimes emerging elsewhere.

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)
  1. [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>

  2. [W3-E2] T1 Derived: Confirmed in_forcehttps://www.pa.gov/agencies/dobs/cybersecurity re-verified

    <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>

  3. [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>

  4. <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>