Key Upcoming Deadlines under the New York DFS Cybersecurity Regulation

When New York’s landmark cybersecurity regulation became effective back in March 2017, the Department of Financial Services (DFS) implemented a two-year timeline for implementation of the regulation’s requirements, with a final compliance deadline of March 1, 2019.  Entities covered by the wide-sweeping regulation should remember filing their first certificate of compliance in February of last year.  The two-year implementation period is almost over, and once again, important deadlines are now quickly approaching.  “Covered Entities” (banks, insurance companies, and other financial services institutions and… Continue Reading

The Glacial Movement of Global Cybersecurity

In the pastoral setting of Le Manoir Richelieu in Charlevoix, Quebec, G7 Summit partners met to discuss a broad spectrum of topics, including the shared values of freedom, democracy, the rule of law, a mutual respect for human rights and common commitment to promote a rules-based international order. Amidst the discussions of freedom, democracy and, yes, tariffs, world leaders issued a “Charlevoix G7 Summit Communique,” which advised: “We will work together to enforce existing international rules and develop new rules where needed, to foster a… Continue Reading

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 hereContinue Reading

NYDFS to Conduct Annual Cyber Assessments on NY Regulated Banks

Governor Andrew Cuomo of New York announced on May 6, 2014 that the New York State Department of Financial Services (NYDFS) would begin conducting “new, regular, targeted cyber security preparedness assessments of the banks [NYDFS] regulates.”  Governor Cuomo noted, Targeted cyber security assessments for banks will better safeguard financial institutions from attacks and secure personal bank records from being breached. When consumers sign up for online banking they expect their personal information to be secure and we are working to make sure financial institutions take… Continue Reading