In light of the recent data privacy breaches at major retailers and that the burden of such breaches hit community banks particularly hard, Office of the Comptroller of the Currency (OCC) Comptroller Curry’s recent speech at the Community Bankers Symposium in Chicago should provide a game plan for community banks and other financial institutions implementing or reviewing their data privacy and information security policies and procedures.  Our recent McGuireWoods Legal Alert provides an in-depth analysis of OCC Comptroller Curry’s remarks on Cybersecurity at Community Banks.