Tag Archives: NYDFS

DFS Partially Clarifies Who Qualifies for an Exemption Under Cybersecurity Regulation

By the terms of 23 NYCRR 500.19(e), Covered Entities that have determined they qualify for a limited exemption from compliance under 23 NYCRR 500.19(a)-(d) of New York’s new Cybersecurity Regulation — as of August 28, 2017 — are required to file a Notice of Exemption with the New York Department of Financial Services (NYDFS) on or prior to September 28, 2017. The first compliance date of August 28, 2017 in New York’s cybersecurity regulation, and the date for Covered Entities to determine whether they qualify…

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New York Issues Final Cybersecurity Regulation

On February 13, 2017, the New York Department of Financial Services (NYDFS) adopted the final version of its first-of-its-kind cybersecurity regulation, “Cybersecurity Requirements For Financial Services Companies” (23 NYCRR 500). This regulation took effect on March 1, 2017. The final regulation reflects several of the comments offered during the final comment period that concluded on January 27, 2017. For a prior list of significant changes from the initial version to the second version, please see our blog post located here. Most of…

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Data Protection

NYDFS Issues Updated Cybersecurity Regulation

The New York Department of Financial Services (NYDFS) recently issued an updated version of its proposed cybersecurity regulation, “Cybersecurity Requirements For Financial Services Companies” (23 NYCRR 500). The updated proposed regulation reflects several of the comments offered during the initial public notice and comment period that concluded on November 14, 2016. Some of the most noteworthy changes in the revision are as follows:

  • Section 500.04 — NYDFS clarified that while a Covered Entity must designate a qualified individual to perform the responsibilities

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NYDFS Notifies Federal Regulators of New Potential Cyber Security Regulations

On November 9, 2015, the New York State Department of Financial Services (NYDFS) sent a memorandum entitled Potential New NYDFS Cyber Security Regulation Requirements to several federal and state financial services regulators, including banking, securities and insurance regulatory, administrative and supervisory  bodies. These potential regulations are based on results of two sets of surveys of financial entities about their “cyber security programs, costs and future plans.” NYDFS surveyed 150 banks and 43 insurance companies. The results of the May 2014 banking industry survey are here

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