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In a surprising turn of events, the New York State Department of Financial Services (“DFS”) announced on December 28 significant changes to its cybersecurity regulation in response to industry concerns that the agency’s original proposal was too prescriptive, and did not allow enough time for compliance.In September of 2016, DFS had proposed stringent cybersecurity requirements aimed at protecting “Nonpublic Information” within the custody or control of banks, insurers, and other financial institutions (“Covered Entities”) from…

The New York State Department of Financial Services (“DFS”) proposed a first-of-its-kind cybersecurity regulation aimed at protecting consumers and financial institutions from cyber-attacks (“Regulation”). The new Regulation, announced by Governor Andrew Cuomo, covers all banks, insurers, and other financial services institutions under DFS’s jurisdiction. It creates new requirements for banks and insurers (“Covered Entities”) to establish and maintain robust controls to protect IT systems against unauthorized access and other malicious acts. Among the list of…