Last week, Sarah Bloom Raskin, Deputy Secretary of the US Department of Treasury, reminded financial institutions of their need to implement and maintain vigilant cybersecurity programs. According to Ms. Bloom Raskin, three critical elements of these programs are to ensure that (1) cybersecurity is embedded in firms’ governance, control and risk management systems; (2) firms regularly engage in “cyber hygiene” (e.g., basic practices to enhance the “security and resilience of computer networks and systems” such as multi-factor authentication to gain access to firms’ networks, systems and data); and (3) firms have a robust response and recovery procedure. Ms. Bloom Raskin’s comments were delivered before the Clearing House Annual Conference on November 17, 2015.