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NYDFS releases major update to Part 500 cybersecurity requirements for financial services companies

Data Protection Report

On November 1, 2023, the New York Department of Financial Services (“NYDFS”) released the finalized amendments of Part 500 of its cybersecurity regulations. This notice requirement explicitly applies to cybersecurity incidents occurring to the covered entity itself, its affiliates, or a third-party service provider.

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Historic Charges: First Enforcement Action Filed by New York Department of Financial Services Under Cybersecurity Regulation

Data Matters

On July 21, 2020, the New York State Department of Financial Services (NYDFS or the Department) issued a statement of charges and notice of hearing (the Statement) against First American Title Insurance Company (First American) for violations of the Department’s Cybersecurity Requirements for Financial Services Companies, 23 N.Y.C.R.R.

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Proposed Amendments to NY Financial Services Cybersecurity Regulations Impose New Obligations on Large Entities, Boards of Directors and CISOs

Hunton Privacy

On July 29, 2022, the New York Department of Financial Services (“NYDFS”) posted proposed amendments (“Proposed Amendments”) to its Cybersecurity Requirements for Financial Services Companies (“Cybersecurity Regulations”). As part of the “access privileges” requirements under Section 500.7

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NYDFS proposes significant cybersecurity regulation amendments

Data Protection Report

On November 9, 2022, the New York Department of Financial Services (NYDFS) officially proposed changes to its cybersecurity regulation and opened a 60-day public comment period. Notice of Cybersecurity Event. NYDFS had issued a “pre-proposed” version of the changes in July of this year, which we had summarized here.

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NYDFS Proposes Updated Second Amendment to Its Cybersecurity Regulation

Hunton Privacy

On June 28, 2023, the New York Department of Financial Services (“NYDFS”) published an updated proposed Second Amendment (“Amendment”) to its Cybersecurity Regulation, 23 NYCRR Part 500. On November 9, 2022, NYDFS published a first draft of the proposed Amendment and received comments from stakeholders over a 60-day period.

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NYDFS Imposes Fine of $5 Million on Carnival for Cybersecurity Breaches

Hunton Privacy

On June 24, 2022, the New York State Department of Financial Services (“NYDFS” or the “Department”) announced it had entered into a $5 million settlement with Carnival Corp. Since Carnival was licensed by the Department to sell insurance in NY State, it was treated as a covered entity under the Cybersecurity Regulation.

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U.S. and Foreign Cybersecurity and Intelligence Agencies Recommend Measures to Counteract Threat of Russian Cyberattacks

Data Matters

Other government agencies, like the New York Department of Financial Services and the Federal Trade Commission, are also increasingly focused on the need for broad implementation of MFA. Like an incident response plan, MFA has become a critical element of cybersecurity programs.