Subject: File No. 4-673
From: Cathy Santoro

March 26, 2014

Specific to Cybersecurity and Market Systems, I am interested to understand how banks and service providers specific to both mobile phones and the Internet are interacting in regards to mobile payment Cybersecurity risks. I am also interested to understand if there are ongoing or planned global discussions between not only banks and mobile phone/Internet service providers but also respective regulatory bodies given the increasingly interconnected global financial markets and continued adoption of mobile phones and smartphones globally. Many of the largest U.S. banks are global in reach and many of the world's largest banks are foreign banks with an active presence in U.S. financial markets and corresponding payment systems. At the same time, these same institutions are also active users of and intermediaries to global financial payment systems, responsible for the movement and flow of trillions of dollars of financial transactions. As reflected in the recent Federal Reserve study specific to mobile financial services, there is increasing growth and adoption of mobile banking by mobile phone and smartphone users (33% and 51% useage, respectively, in the last year - an increase of 28% and 48%, respectively, since December 2012). Given that a significant percentage of the global population is in developing countries where access to banking is limited and remains unbanked, with certain segments of said population living in or near countries with higher risk of violence and terrorism, and is increasingly adopting mobile phone/smartphone technology, I believe that risk to financial payment flows can increase exponentially in the absence of coordinated and/or collaborative discussion. Accordingly, I would be interested to gain additional insights specific to these points.

Thank you.

Best regards,
Cathy Santoro