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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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SEC Announces Settled Charges Against First American for Cybersecurity Disclosure Controls Failures – Lessons Learned

Data Matters

In the Order, the SEC alleges that First American’s disclosures concerning the vulnerability were deficient because senior executives were not provided all available and relevant information, specifically that First American’s information security personnel had identified and failed to remediate the vulnerability months earlier in January 2019.