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Cybersecurity Risk Management and Strategy
12 Months Ended
Dec. 31, 2024
Cybersecurity risk management Strategy and Governance [Abstract]  
Cybersecurity Risk Management Processes For Assessing Identifying And Managing Threats [Text Block]
The
 
Corporation
 
assesses,
 
identifies
 
and
 
manages
 
cybersecurity
 
risk
 
as
 
part
 
of
 
the
 
Corporation’s
 
overall
 
risk
 
management
framework, alongside
 
associated information
 
security,
 
anti-money laundering
 
and counterterrorism,
 
operational, fraud,
 
regulatory,
legal and reputational risks, among others.
 
The Corporation has established three management
 
committees that oversee and monitor different aspects of
 
cybersecurity risk.
 
The
 
Enterprise Risk
 
Management Committee
 
(the “ERM
 
Committee”), chaired
 
by
 
the Chief
 
Risk Officer,
 
oversees and
monitors
 
the
 
risks
 
included
 
in
 
the
 
Risk Appetite
 
Statement
 
(the
 
“RAS”)
 
of
 
the
 
Corporation’s
 
Risk
 
Management
 
Policy,
including cybersecurity risks.
 
 
The Information
 
Technology and
 
Cyber Risk
 
Committee (“ITCRC”),
 
chaired by
 
the Chief
 
Security
 
Officer and
 
the Chief
Information and
 
Digital Strategy
 
Officer, oversees
 
and monitors
 
information technology
 
(“IT”), privacy
 
and cybersecurity
risks, mitigating
 
actions and
 
controls, applicable
 
regulatory developments, key
 
risks metrics,
 
and IT
 
and cyber
 
incidents
that may result in operational, compliance and reputational
 
risks.
 
The
 
Operational
 
Risk
 
Committee (“ORCO”),
 
chaired
 
by
 
the
 
Chief Risk
 
Officer,
 
oversees
 
and
 
monitors
 
operational
 
risk
management activities
 
to ensure
 
the development
 
and consistent
 
application of
 
operational risk
 
policies, processes
 
and
procedures that
 
measure, limit
 
and manage
 
the Corporation's
 
operational risks
 
while maintaining
 
the effectiveness
 
and
efficiency
 
of
 
the
 
operating and
 
business
 
processes. As
 
part
 
of
 
its
 
responsibilities, ORCO
 
oversees business
 
continuity
matters, as well as operational losses stemming
 
from any cybersecurity or fraud events.
The ITCRC and ORCO meet at least quarterly
 
and report on cybersecurity and other matters
 
to the ERM Committee.
The Board
 
has also established
 
a Board-level Risk
 
Management Committee (“RMC”),
 
which is responsible
 
for the
 
oversight of the
Corporation’s overall risk framework, and assists the Board in the monitoring, review and approval of the policies that measure, limit
and manage the Corporation’s risks, including cybersecurity
 
risk. The RMC holds periodic meetings in
 
which management provides
an
 
overview of
 
Popular’s cybersecurity
 
threat
 
risk management
 
and strategy
 
processes,
 
which includes
 
summaries
 
of
 
escalated
incidents
 
and
 
incident
 
remediation
 
status.
 
Our
 
Chief
 
Security
 
Officer,
 
Chief
 
Information
 
and
 
Digital
 
Strategy
 
Officer,
 
Chief
Information Security Officer
 
(“CISO”), Chief Risk
 
Officer and the
 
Financial and Operational
 
Risk Management Division
 
(the “FORM
Division”)
 
Manager
 
generally
 
participate
 
in
 
such
 
meetings.
 
The
 
RMC
 
is
 
also
 
responsible
 
for
 
(i)
 
overseeing
 
the
 
development,
implementation
 
and
 
maintenance
 
of
 
the
 
Corporation’s
 
information
 
security
 
program
 
(the
 
“Information
 
Security
 
Program”);
 
(ii)
approving the Corporation’s risk management program
 
and any related policies and controls;
 
(iii) overseeing the implementation by
the Corporation’s
 
management of
 
the Corporation’s
 
risk management
 
program and
 
any related
 
policies, procedures
 
and controls;
and (iv) reviewing reports regarding selected topics
 
such as cyber.
The Board in turn also receives briefings on cybersecurity matters and risks, including an annual presentation from the Chief
Security Officer and the CISO on the Information Security Program.
In
 
addition,
 
as
 
part
 
of
 
the
 
Board’s
 
director
 
education
 
plan,
members of the
 
Board take, on
 
an annual basis,
 
a cybersecurity training that
 
provides the Board with
 
an overview of
 
cybersecurity
principles and regulations that are relevant to our institution
 
and the Board’s oversight function.
To identify, assess and manage risks from cybersecurity threats, the Corporation has established a three lines of defense
framework. The first line of defense is composed of business line management that identifies and manages the risks associated with
business activities, including cybersecurity risk. The second line of defense is made up of members of the Corporation’s Corporate
Risk Management Group and the Corporate Security Group (the “CSG”) who, among other things, measure and report on the
Corporation’s risk activities. In such line of defense, the FORM Division, within the Corporate Risk Management Group, is
responsible for (i) establishing baseline metrics that measure, monitor, limit and manage the framework that identifies and manages
multiple and cross-enterprise risks, including cybersecurity risks; and (ii) articulating the RAS and supporting metrics, including
those related to operational risk, business continuity, disaster recovery and third-party management oversight processes.
Meanwhile, Popular’s Cyber Security Division (the “CSD”), which is headed by the CISO and reports to the CSG, is responsible for
the development of strategies, policies and programs to assess and mitigate cybersecurity risks. Members of the CSD (including the
CISO) and FORM Division report on and escalate cybersecurity, IT and privacy risks to management committees, such as the
ITCRC, ORCO and ERM Committee, and, if appropriate, to the RMC and the Board of Directors, as required under relevant policies
and procedures. Lastly, the third line of defense consists of the Corporate Auditing Division, which independently provides
assurance regarding the effectiveness of the risk framework and reports directly to the Audit Committee of the Board.
Popular monitors various vectors of threats and utilizes open-source intelligence forums and communities such as the Financial
Services Information Sharing and Analysis Center and the Cybersecurity and Infrastructure Security Agency, among others, to
receive threat intelligence feeds which are reviewed by the CSD. As cybersecurity threats are identified, they are evaluated to
assess the level of exposure and the potential risk to Popular. The ITCRC and the ERM Committee discuss and track the threats
identified in internal assessments and scans or in third-party reports. Depending on the evolution and materiality of the threat, these
are escalated to the RMC as appropriate.
The CSD
 
develops the
 
Information Security Program,
 
which considers and
 
evaluates risks
 
posed by
 
cybersecurity threats,
 
events
and
 
activities
 
impacting
 
the
 
industry
 
and
 
the
 
Corporation.
 
The
 
Information
 
Security
 
Program
 
outlines
 
the
 
Corporation’s
 
overall
strategy and
 
governance to
 
protect the
 
confidentiality,
 
integrity and
 
availability of
 
information and
 
prevent access
 
by unauthorized
personnel, and is based on standards and controls set by the National Institute of Standards and Technology
 
(“NIST”), including the
NIST’s Framework for
 
Improving Critical Infrastructure
 
Cybersecurity. Popular
 
currently leverages the
 
Cyber Assessment Tool
 
(the
“CAT”), a tool based on NIST standards and controls developed by the Federal Financial Institutions
 
Examination Council (“FFIEC”),
in order to measure the
 
Corporation’s cybersecurity preparedness and maturity levels.
 
The CAT
 
assessment results are integrated
into
 
the overall
 
Information Security
 
Program evaluation.
 
In
 
2025, we
 
will
 
transition to
 
the Cyber
 
Risk Institute
 
(“CRI”) Profile
 
2.0
assessment framework, following the announcement by the FFIEC of the sunset
 
of the CAT in
 
2025. The CRI Profile was produced
through public-private collaboration and is a list of assessment questions curated based
 
on the intersection of global regulations and
cyber standards, such as the International Standards
 
Organization (ISO) and the NIST.
 
The CSD
 
also manages the
 
Incident Response Program
 
(“IRP”) of the
 
Corporation and is
 
in charge of
 
overseeing, assessing and
managing cyber
 
incidents. The
 
IRP outlines
 
the measures
 
Popular must
 
take to
 
prepare for,
 
detect, respond
 
to and
 
recover from
cybersecurity
 
incidents,
 
which
 
include
 
processes
 
to
 
triage,
 
assess
 
severity
 
for,
 
escalate,
 
contain,
 
investigate
 
and
 
remediate
incidents, as well as to comply with potentially
 
applicable legal obligations and mitigate brand
 
and reputational damage.
 
The Corporation also undertakes the below listed
 
additional activities in its effort
 
to maintain regulatory compliance, identify,
 
assess
and manage its material risks from cybersecurity
 
threats, and to protect against, detect and
 
respond to cybersecurity incidents:
 
 
Conduct
 
tabletop
 
exercises
 
that
 
simulate
 
cybersecurity
 
incidents
 
to
 
raise
 
awareness
 
and
 
enhance
 
Popular’s
 
responsive
measures;
 
Assess how business
 
and corporate strategies, new
 
products, technology deployments, external
 
events and the
 
evolution of
threats impact
 
the Corporation’s
 
information security
 
controls in
 
order to
 
determine if
 
they require
 
any additional
 
resources,
technology or processes;
 
Discuss cybersecurity risks with law enforcement, peer
 
groups, industry forums and trade associations;
 
Provide training
 
to all
 
Popular employees
 
upon hiring
 
and annually
 
thereafter on
 
cybersecurity and
 
customer data
 
handling
and use requirements;
 
Offer training and awareness campaigns to customers and employees
 
based on their role;
 
 
Conduct
 
phishing
 
simulations
 
for
 
employees,
 
with
 
escalation
 
protocols
 
for
 
employees
 
that
 
fail
 
such
 
tests
 
to
 
enhance
awareness and responsiveness to such possible
 
threats;
 
Offer learning and development opportunities to employees
 
who handle and manage cybersecurity matters;
 
Carry cyber insurance to provide protection against
 
potential losses arising from cybersecurity incidents;
 
and
 
Monitor emerging
 
legal and
 
regulatory requirements
 
and implement
 
changes to
 
our processes,
 
policies and
 
statements, as
necessary.
Popular engages third parties to assist in certain cybersecurity matters.
In particular, Popular uses the expertise of third parties to
perform specialized assessments to test its systems, such as periodic penetration testing, that provide insights into the effectiveness
of its controls. Popular also engages third parties to provide computer forensics and investigations services as needed to assess
and address actual or potential cybersecurity incidents. In addition, Popular hires third parties to provide the first level security
monitoring of Popular’s external and internal networks.
 
Popular’s Outsourced
 
Risk Management
 
Policy
 
outlines the
 
management of
 
risks
 
associated with
 
the Corporation’s
 
use
 
of third-
party service
 
providers, and
 
the CSG
 
assesses the
 
impact and
 
level of
 
cybersecurity and
 
privacy risk
 
of such
 
providers. Popular
performs due diligence on
 
third parties and monitors third
 
parties that have access to
 
its systems, data or facilities
 
that house such
systems or data on a
 
periodic basis, and based on due
 
diligence results, determines how often vendor assessments are
 
performed
on such third party.
 
Popular also conducts periodic application and vendor assessments for third-party providers
 
and their products.
Furthermore, Popular requires third parties that have
 
access to its systems, data or facilities that house
 
such systems or data to take
a training on cybersecurity at least annually.
Under the heading “We and our third-party providers have been, and expect in the future to continue to be, subject to cyber-attacks,
which could cause
 
substantial harm and
 
have an adverse
 
effect on our
 
business and results
 
of operations.” and
 
“We rely on
 
other
companies to
 
provide key components
 
of our
 
business infrastructure, including
 
certain of
 
our core financial
 
transaction processing
and information
 
technology and
 
security services,
 
which exposes
 
us to
 
a number
 
of
 
operational risks
 
that could
 
have a
 
material
adverse
 
effect
 
on
 
us.”,
 
included
 
as
 
part
 
of
 
our
 
risk
 
factor
 
disclosures
 
in
 
Item
 
1A
 
in
 
this
 
Form
 
10-K,
 
which
 
disclosures
 
are
incorporated by
 
reference herein,
we describe whether and how risks from identified cybersecurity threats, including as a result of
any previous cybersecurity incidents, could have materially affected or are reasonably likely to materially affect us, including our
business strategy, results of operations, or financial condition.
The CSG
 
operates under
 
the direction
 
of the
 
Chief Security
 
Officer.
 
The Chief
 
Security Officer
 
has over
 
36 years
 
of experience,
including over 12 years of
 
professional experience in information technology and cybersecurity matters such
 
as the oversight of the
Information
 
Security
 
Program
 
and
 
the
 
design
 
and
 
execution
 
of
 
the
 
information
 
security
 
audit
 
plan
 
of
 
the
 
Corporation.
 
She
 
is
 
a
Certified Public Accountant that also holds a Juris Doctor degree and FINRA administered
 
Series 7 and Series 27 certifications. She
holds the title
 
of Executive Vice
 
President and Chief Security
 
Officer and has been
 
in her role
 
since 2018. Prior to
 
that, she served
as Senior
 
Vice President
 
and General
 
Auditor of
 
the Corporation
 
from November
 
2012 to
 
April 2018.
 
Before 2012,
 
she served
 
in
various risk
 
related functions of
 
the Corporation and
 
as the Chief
 
Operating Officer
 
and Chief Financial
 
Officer of
 
Popular’s broker
dealer business.
The
 
CISO
 
has
 
over
 
26
 
years
 
of
 
work
 
experience
 
in
 
various
 
roles
 
in
 
major
 
financial
 
institutions
 
involving
 
leading
 
top-level
cybersecurity governance
 
strategy and
 
initiatives, integrating
 
security
 
governance into
 
the overall
 
business strategy
 
and advising
boards of directors on cyber risks and cybersecurity standards.
 
He has been a certified information security professional since 2007.
He holds the title of CISO and Cybersecurity Division
 
Manager and has been in this role since
 
2019.
 
The Corporate Risk
 
Management Group operates under
 
the direction of
 
the Chief Risk
 
Officer. The
 
Chief Risk Officer
 
has over 31
years of work experience.
 
He holds the title of Executive Vice President and
 
Chief Risk Officer and has been in
 
his role since 2011.
Prior to
 
joining the
 
Corporation, he served
 
for 17
 
years as
 
Chief Financial
 
Officer,
 
Head of
 
Retail Bank
 
and Mortgage
 
Operations,
Head of Commercial and Construction Mortgage and
 
Head of Interest Rate Risk, among
 
other positions, for other banks.
 
He holds
a BS with a major in Computer Engineering
 
and an MBA with majors in Finance and
 
Accounting.
The FORM Division Manager has over 29 years of work experience.
 
She holds the title of Senior Vice President and FORM Division
Manager
 
and
 
has
 
been
 
in
 
her
 
role
 
since
 
March
 
2022.
 
Prior
 
to
 
that
 
she
 
held
 
positions
 
for
 
16
 
years
 
as
 
Operational
 
and
 
IT
 
Risk
Director,
 
Head
 
of
 
ERM
 
and
 
Operational Risk,
 
and
 
Chief
 
Information Security
 
Officer
 
for
 
other
 
banks. She
 
also
 
held
 
positions in
Internal
 
Audit
 
and
 
IT
 
Management
 
for
 
other
 
industries
 
throughout
 
her
 
career.
 
She
 
holds
 
a
 
BBA
 
with
 
majors
 
in
 
Accounting
 
and
Information Systems, and a Master of Science in Information
 
Technology Management.
Cybersecurity Risk Management Processes Integrated [Flag] true
Cybersecurity Risk Management Processes Integrated [Text Block]
To identify, assess and manage risks from cybersecurity threats, the Corporation has established a three lines of defense
framework. The first line of defense is composed of business line management that identifies and manages the risks associated with
business activities, including cybersecurity risk. The second line of defense is made up of members of the Corporation’s Corporate
Risk Management Group and the Corporate Security Group (the “CSG”) who, among other things, measure and report on the
Corporation’s risk activities. In such line of defense, the FORM Division, within the Corporate Risk Management Group, is
responsible for (i) establishing baseline metrics that measure, monitor, limit and manage the framework that identifies and manages
multiple and cross-enterprise risks, including cybersecurity risks; and (ii) articulating the RAS and supporting metrics, including
those related to operational risk, business continuity, disaster recovery and third-party management oversight processes.
Meanwhile, Popular’s Cyber Security Division (the “CSD”), which is headed by the CISO and reports to the CSG, is responsible for
the development of strategies, policies and programs to assess and mitigate cybersecurity risks. Members of the CSD (including the
CISO) and FORM Division report on and escalate cybersecurity, IT and privacy risks to management committees, such as the
ITCRC, ORCO and ERM Committee, and, if appropriate, to the RMC and the Board of Directors, as required under relevant policies
and procedures. Lastly, the third line of defense consists of the Corporate Auditing Division, which independently provides
assurance regarding the effectiveness of the risk framework and reports directly to the Audit Committee of the Board.
The Corporation also undertakes the below listed
 
additional activities in its effort
 
to maintain regulatory compliance, identify,
 
assess
and manage its material risks from cybersecurity
 
threats, and to protect against, detect and
 
respond to cybersecurity incidents:
 
 
Conduct
 
tabletop
 
exercises
 
that
 
simulate
 
cybersecurity
 
incidents
 
to
 
raise
 
awareness
 
and
 
enhance
 
Popular’s
 
responsive
measures;
 
Assess how business
 
and corporate strategies, new
 
products, technology deployments, external
 
events and the
 
evolution of
threats impact
 
the Corporation’s
 
information security
 
controls in
 
order to
 
determine if
 
they require
 
any additional
 
resources,
technology or processes;
 
Discuss cybersecurity risks with law enforcement, peer
 
groups, industry forums and trade associations;
 
Provide training
 
to all
 
Popular employees
 
upon hiring
 
and annually
 
thereafter on
 
cybersecurity and
 
customer data
 
handling
and use requirements;
 
Offer training and awareness campaigns to customers and employees
 
based on their role;
 
 
Conduct
 
phishing
 
simulations
 
for
 
employees,
 
with
 
escalation
 
protocols
 
for
 
employees
 
that
 
fail
 
such
 
tests
 
to
 
enhance
awareness and responsiveness to such possible
 
threats;
 
Offer learning and development opportunities to employees
 
who handle and manage cybersecurity matters;
 
Carry cyber insurance to provide protection against
 
potential losses arising from cybersecurity incidents;
 
and
 
Monitor emerging
 
legal and
 
regulatory requirements
 
and implement
 
changes to
 
our processes,
 
policies and
 
statements, as
necessary.
Cybersecurity Risk Management Third Party Engaged [Flag] true
Cybersecurity Risk Third Party Oversight And Identification Processes [Flag] true
Cybersecurity Risk Process For Informing Board Committee Or Subcommittee Responsible For Oversight [Text Block]
The Board
 
has also established
 
a Board-level Risk
 
Management Committee (“RMC”),
 
which is responsible
 
for the
 
oversight of the
Corporation’s overall risk framework, and assists the Board in the monitoring, review and approval of the policies that measure, limit
and manage the Corporation’s risks, including cybersecurity
 
risk. The RMC holds periodic meetings in
 
which management provides
an
 
overview of
 
Popular’s cybersecurity
 
threat
 
risk management
 
and strategy
 
processes,
 
which includes
 
summaries
 
of
 
escalated
incidents
 
and
 
incident
 
remediation
 
status.
 
Our
 
Chief
 
Security
 
Officer,
 
Chief
 
Information
 
and
 
Digital
 
Strategy
 
Officer,
 
Chief
Information Security Officer
 
(“CISO”), Chief Risk
 
Officer and the
 
Financial and Operational
 
Risk Management Division
 
(the “FORM
Division”)
 
Manager
 
generally
 
participate
 
in
 
such
 
meetings.
 
The
 
RMC
 
is
 
also
 
responsible
 
for
 
(i)
 
overseeing
 
the
 
development,
implementation
 
and
 
maintenance
 
of
 
the
 
Corporation’s
 
information
 
security
 
program
 
(the
 
“Information
 
Security
 
Program”);
 
(ii)
approving the Corporation’s risk management program
 
and any related policies and controls;
 
(iii) overseeing the implementation by
the Corporation’s
 
management of
 
the Corporation’s
 
risk management
 
program and
 
any related
 
policies, procedures
 
and controls;
and (iv) reviewing reports regarding selected topics
 
such as cyber.
The Board in turn also receives briefings on cybersecurity matters and risks, including an annual presentation from the Chief
Security Officer and the CISO on the Information Security Program.
Cybersecurity Risk Materially Affected Or Reasonably Likely To Materially Affect Registrant [Flag] false
Cybersecurity Risk Board Of Directors Oversight [Text Block]
In
 
addition,
 
as
 
part
 
of
 
the
 
Board’s
 
director
 
education
 
plan,
members of the
 
Board take, on
 
an annual basis,
 
a cybersecurity training that
 
provides the Board with
 
an overview of
 
cybersecurity
principles and regulations that are relevant to our institution
 
and the Board’s oversight function.
Cybersecurity Risk Board Committee Or Subcommittee Responsible For Oversight [Text Block]
The Corporation has established three management
 
committees that oversee and monitor different aspects of
 
cybersecurity risk.
 
The
 
Enterprise Risk
 
Management Committee
 
(the “ERM
 
Committee”), chaired
 
by
 
the Chief
 
Risk Officer,
 
oversees and
monitors
 
the
 
risks
 
included
 
in
 
the
 
Risk Appetite
 
Statement
 
(the
 
“RAS”)
 
of
 
the
 
Corporation’s
 
Risk
 
Management
 
Policy,
including cybersecurity risks.
 
 
The Information
 
Technology and
 
Cyber Risk
 
Committee (“ITCRC”),
 
chaired by
 
the Chief
 
Security
 
Officer and
 
the Chief
Information and
 
Digital Strategy
 
Officer, oversees
 
and monitors
 
information technology
 
(“IT”), privacy
 
and cybersecurity
risks, mitigating
 
actions and
 
controls, applicable
 
regulatory developments, key
 
risks metrics,
 
and IT
 
and cyber
 
incidents
that may result in operational, compliance and reputational
 
risks.
 
The
 
Operational
 
Risk
 
Committee (“ORCO”),
 
chaired
 
by
 
the
 
Chief Risk
 
Officer,
 
oversees
 
and
 
monitors
 
operational
 
risk
management activities
 
to ensure
 
the development
 
and consistent
 
application of
 
operational risk
 
policies, processes
 
and
procedures that
 
measure, limit
 
and manage
 
the Corporation's
 
operational risks
 
while maintaining
 
the effectiveness
 
and
efficiency
 
of
 
the
 
operating and
 
business
 
processes. As
 
part
 
of
 
its
 
responsibilities, ORCO
 
oversees business
 
continuity
matters, as well as operational losses stemming
 
from any cybersecurity or fraud events.
Cybersecurity Risk Role Of Management [Text Block]
The Board
 
has also established
 
a Board-level Risk
 
Management Committee (“RMC”),
 
which is responsible
 
for the
 
oversight of the
Corporation’s overall risk framework, and assists the Board in the monitoring, review and approval of the policies that measure, limit
and manage the Corporation’s risks, including cybersecurity
 
risk. The RMC holds periodic meetings in
 
which management provides
an
 
overview of
 
Popular’s cybersecurity
 
threat
 
risk management
 
and strategy
 
processes,
 
which includes
 
summaries
 
of
 
escalated
incidents
 
and
 
incident
 
remediation
 
status.
 
Our
 
Chief
 
Security
 
Officer,
 
Chief
 
Information
 
and
 
Digital
 
Strategy
 
Officer,
 
Chief
Information Security Officer
 
(“CISO”), Chief Risk
 
Officer and the
 
Financial and Operational
 
Risk Management Division
 
(the “FORM
Division”)
 
Manager
 
generally
 
participate
 
in
 
such
 
meetings.
 
The
 
RMC
 
is
 
also
 
responsible
 
for
 
(i)
 
overseeing
 
the
 
development,
implementation
 
and
 
maintenance
 
of
 
the
 
Corporation’s
 
information
 
security
 
program
 
(the
 
“Information
 
Security
 
Program”);
 
(ii)
approving the Corporation’s risk management program
 
and any related policies and controls;
 
(iii) overseeing the implementation by
the Corporation’s
 
management of
 
the Corporation’s
 
risk management
 
program and
 
any related
 
policies, procedures
 
and controls;
and (iv) reviewing reports regarding selected topics
 
such as cyber.
Cybersecurity Risk Management Positions Or Committees Responsible [Flag] true
Cybersecurity Risk Management Positions Or Committees Responsible [Text Block]
Popular monitors various vectors of threats and utilizes open-source intelligence forums and communities such as the Financial
Services Information Sharing and Analysis Center and the Cybersecurity and Infrastructure Security Agency, among others, to
receive threat intelligence feeds which are reviewed by the CSD. As cybersecurity threats are identified, they are evaluated to
assess the level of exposure and the potential risk to Popular. The ITCRC and the ERM Committee discuss and track the threats
identified in internal assessments and scans or in third-party reports. Depending on the evolution and materiality of the threat, these
are escalated to the RMC as appropriate.
Cybersecurity Risk Process For Informing Management Or Committees Responsible [Text Block]
The ITCRC and ORCO meet at least quarterly
 
and report on cybersecurity and other matters
 
to the ERM Committee.
Cybersecurity Risk Management Expertise Of Management Responsible [Text Block]
The CSG
 
operates under
 
the direction
 
of the
 
Chief Security
 
Officer.
 
The Chief
 
Security Officer
 
has over
 
36 years
 
of experience,
including over 12 years of
 
professional experience in information technology and cybersecurity matters such
 
as the oversight of the
Information
 
Security
 
Program
 
and
 
the
 
design
 
and
 
execution
 
of
 
the
 
information
 
security
 
audit
 
plan
 
of
 
the
 
Corporation.
The
 
CISO
 
has
 
over
 
26
 
years
 
of
 
work
 
experience
 
in
 
various
 
roles
 
in
 
major
 
financial
 
institutions
 
involving
 
leading
 
top-level
cybersecurity governance
 
strategy and
 
initiatives, integrating
 
security
 
governance into
 
the overall
 
business strategy
 
and advising
boards of directors on cyber risks and cybersecurity standards.
The Corporate Risk
 
Management Group operates under
 
the direction of
 
the Chief Risk
 
Officer. The
 
Chief Risk Officer
 
has over 31
years of work experience.
The FORM Division Manager has over 29 years of work experience.
Cybersecurity Risk Management Positions Or Committees Responsible Report To Board [Flag] true