locations · wilmington

Card issuers and registered agents in one small city, both guarding data that belongs to someone else.

Credit card banks came to Wilmington after the 1981 banking law, and the state's corporate code brought trust companies and registered agents. One side holds cardholder accounts for the whole country. The other holds formation papers and officer details for millions of entities.

in short·15-second read

In Wilmington we work with card issuers and consumer banks, trust and corporate service companies, and insurers.

Typical work is customer identity and fraud-resistant sign-in, privileged access for card platforms, access governance over entity and client records, and the evidence boards need to show they oversee cyber risk. We're based in Frisco, Texas, serve Delaware clients remotely, and travel in for workshops and launches.

We don't have a Delaware office. Cohash runs Wilmington engagements from Frisco, Texas, works remotely day to day, and sends people in for discovery workshops, board or risk committee briefings and go-live.

Ask an engineer facts checked 2026-10-21 · 8 sources
rules
Delaware breach notification, 6 Del. C. §12B-102Delaware Personal Data Privacy Act, 6 Del. C. ch. 12DDelaware Insurance Data Security Act, 18 Del. C. ch. 86
who and what

Who we work with in Wilmington, Delaware, and the rules they work under

industries
  1. Credit card issuers and consumer banks

    Card platforms carry tens of millions of customer logins, call center agents who can change contact details, and processors with standing API access. Account takeover usually starts with a phone number change. We add step-up checks to profile changes, vault the privileged accounts that run the card platform, and put processor credentials on rotation.

  2. Trust companies, registered agents and corporate services

    These firms hold formation documents, officer lists and ownership data for client entities, often in one case management system that every service rep can search. We scope access to the client portfolio a person actually serves, log bulk exports, and give clients and their law firms a separate portal identity with MFA.

  3. Board oversight of cyber risk

    Chancery decisions keep pleading standards high, but they also show boards are asked what reports they received and when. We set up identity and access metrics that go to the risk committee on a schedule, such as privileged account counts, MFA gaps and overdue reviews, so there is a record of oversight.

  4. Insurers domiciled in Delaware

    Delaware's insurance data security law asks for a written program and a fast report to the Commissioner. We document how vendor and agent access is granted, reviewed and removed, which is usually the weakest part of the program on paper.

regulations
  1. Delaware breach notification, 6 Del. C. §12B-102 ↗

    Residents must be told without unreasonable delay and no later than 60 days after the breach is determined. The Attorney General is notified too when more than 500 residents are affected, and a breach involving Social Security numbers requires one year of free credit monitoring.

  2. Delaware Personal Data Privacy Act, 6 Del. C. ch. 12D ↗

    In force since 1 January 2025 for controllers handling data of at least 35,000 consumers, with no general nonprofit exemption. The mandatory 60-day cure period ended after 2025, opt-out signals had to be honored by 1 January 2026, and amendments lower the thresholds to 10,000 consumers from 1 January 2027.

  3. Delaware Insurance Data Security Act, 18 Del. C. ch. 86 ↗

    Licensees keep a written information security program, with an exemption for those under 15 employees. Qualifying cybersecurity events go to the Insurance Commissioner no later than 3 business days after the licensee determines one occurred.

01Does the Delaware privacy law apply to our nonprofit?

It can. Delaware didn't give nonprofits a blanket exemption the way several other states did, so a nonprofit over the consumer threshold is generally in scope. The thresholds drop to 10,000 consumers on 1 January 2027, which pulls in smaller organizations. Confirm your status with counsel.

02How fast do we have to notify after a breach in Delaware?

Residents within 60 days of determining the breach, unless federal law sets a shorter period or law enforcement asks you to wait. The Attorney General hears from you at the same time if more than 500 residents are affected. Insurers have a separate 3-business-day report to the Commissioner.

03Can you help our board show it oversees cyber risk?

We can give it something to oversee. That means a short, regular identity risk report with privileged account counts, MFA coverage, stale access and vendor access, plus the decisions taken on each. How the board minutes and discusses it is for your general counsel and corporate secretary.

04Our service reps can search every client entity. Is that normal?

It's common, and it's the exposure we'd fix first. Most reps serve a defined book of clients. Scoping search to that book, with a logged break-glass path for exceptions, cuts the damage one stolen login can do.

sources 8 sources linked last checked 2026-10-21 content fingerprint 18dfe5a5
  1. 01Delaware Division of Corporations, annual report statistics (2025)corp.delaware.gov ↗
  2. 02Technical.ly, why so many banks are in Wilmington (updated April 2026)technical.ly ↗
  3. 03BLS, Delaware economy at a glancebls.gov ↗
  4. 04Harvard Law School Forum, Chancery court on Caremark and cybersecurity risk (SolarWinds)corpgov.law.harvard.edu ↗
  5. 05Delaware Code title 6, chapter 12Bdelcode.delaware.gov ↗
  6. 06Delaware Code title 6, chapter 12Ddelcode.delaware.gov ↗
  7. 07Baker Donelson, Delaware consumer data privacy law guidebakerdonelson.com ↗
  8. 08Delaware Code title 18, chapter 86delcode.delaware.gov ↗
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