And, of course, the Dodd-Frank Act created the FSOC—an unusual entity in U.S. administrative law. Appreciating this new configuration of authorities is important as a positive matter for understanding how regulation will be shaped over time and identifying possible remaining gaps in regulatory authority. It is also important as a normative matter in considering whether the allocation of authorities proves optimal over time.
Third, the BSP continuously engages with the BSFIs through the Bankers Association of the Philippines Cyber Incident Database or BAPCID. BAPCID is currently provided by CyberInt, which is a cybersecurity service provider based in Israel.