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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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An Approach to Cybersecurity Risk Oversight for Corporate Directors

Data Matters

Encrypting critical data assets. Board-management discussions about cyber risk should include identification of which risks to avoid, which to accept, and which to mitigate or transfer through insurance, as well as specific plans associated with each approach. Creating an enterprise-wide governance structure. Principle 5.