NYS Cyber Crack Down Looms: What Every Financial Institution, Insurer and Their Board Must Know

October 20, 2016

With the public comment period closing in a few days, the New York Department of Financial Services (DFS) “first in the nation” cybersecurity regulation is one step closer to becoming law.  The regulation – which covers a broad swath of the world’s financial and insurance communities by virtue of DFS’s presence in the epicenter of the financial world – mandates a broad array of powerful and detailed requirements that far exceed existing federal and state cyber regulation.  Indeed, the regulation contains unprecedented requirements, such as board “review” of a required 14-point comprehensive cybersecurity policy and the written certification by a senior corporate officer verifying compliance with the regulation.

The DFS regulation covers more than 3,000 financial institutions and insurers – including foreign and non-New York based entities – that operate by virtue of New York banking, insurance or financial services laws.

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