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New York State's Financial Services Cybersecurity Regulation

By Elizabeth B. Vandesteeg and Kathryn C. Nadro
March 02, 2017

New York is poised to become the first state in the nation with comprehensive cybersecurity regulation and reporting requirements applicable to the entire financial services industry, with only very limited exemptions. 23 NYCRR 500 (the Regulation) will require banks, insurance companies, and other financial institutions regulated by the New York State Department of Financial Services (DFS) to establish and maintain a cybersecurity program designed to protect consumers and the stability of New York's financial services industry. The Regulation was designed to promote the protection of customer information as well as the underlying information technology systems of regulated entities in light of the ever-increasing threat of cyber attacks. It requires assessment of specific risk profile and design of program addressing risks, for which senior management is responsible including annual certification of compliance.

Originally intended to go into effect on Jan. 1, 2017, the Regulation received substantial industry comment and push-back. In response, DFS released a revised draft of the Regulation which was open to an additional 30-day comment period, extending the Regulation's effective date to March 1, 2017.

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