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NY Department of Financial Services issues updated cybersecurity regulation
As we previously reported, the New York Department of Financial Services (NYDFS) issued a cybersecurity regulation for regulated financial services companies effective on January 1, 2017. The proposed regulation met with significant opposition and concerns in comments submitted to NYDFS. Concerns included inconsistencies between federal and state requirements and the impact of a company’s size upon its ability to meet the cybersecurity requirements. In response, NYDFS recently announced that it would extend the compliance date to allow regulated companies additional time to understand and implement the requirements.
On December 28, Financial Services Superintendent Maria T. Vullo announced that NYDFS “has updated its proposed first-in-the-nation cybersecurity regulation to protect New York State from the ever-growing threat of cyberattacks.” The proposed regulation will take effect on March 1, 2017, which will require banks, insurance companies and other regulated financial services institutions to “establish and maintain a cybersecurity program designed to protect consumers and ensure the safety and soundness of New York State’s financial services industry.”
NYDFS has stated that it carefully considered the comments expressed regarding the initially proposed regulation. It submits that it has incorporated the comments into the updated version of the regulation, which is now subject to an additional final 30-day comment period. NYDFS will focus its final review on any new comments that were not previously raised during the original comment period.
We will analyze and report on the updated cybersecurity regulation, which may be found here.


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