Solicitation for Public Comments on the Business Practices of Cloud Computing Providers

See attached comment letter from the American Bankers Association (ABA). The ABA urges the FTC to leverage the work of the US Treasury Department and Federal banking agencies (FBAs) and align as much as possible with other agencies and foreign authorities so that there is a harmonized approach to the safe and sound financial sector adoption of cloud services. In addition, the ABA encourages cloud service providers (CSPs) to include design features within their base products and services offerings that allow banks to meet their compliance requirements for security and resiliency. The ABA letter discusses challenges with negotiating contracts with CSPs, conducting due diligence and ongoing monitoring, managing concentration risk and dependencies on CSPs, and migration from one cloud provider to another. Many banks utilize cloud services to respond to customer demands for digital products, increase resilience to physical and cyber security incidents, leverage cost efficiencies relative to maintaining legacy IT systems, and to support a remote workforce.