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NY DFS Proposed Cybersecurity Regulations Revised and Implementation Delayed

We previously reported on the New York Department of Financial Services’ proposed cybersecurity regulations. During the public comment period, the DFS received over 150 comments. In response, the DFS announced on December 28,...more

New York Department of Financial Services Revises Proposed Cybersecurity Rule

The New York Department of Financial Services (NYDFS) recently issued a revised proposed regulation seeking to add its own mandate of cybersecurity requirements to those already in existence for banks, insurance companies and...more

2017 Insurance & Risk Management Checklist

As we start a new year, it is important to evaluate your company’s insurance and risk management program and plan for the year. Following up on our 2016 checklist, we have updated steps to take and things to consider for your...more

How Distributed Ledger Technology Might Grow in the Insurance Industry

On Jan. 5, 2017, the Department of Treasury Federal Insurance Office held its first committee meeting of the new year. Several topics were addressed, including the use of blockchain/distributed ledger technology (“DLT”) in...more

New York State Revises “First-In-Nation” Cybersecurity Rules

The New York Department of Financial Services (“DFS”) recently issued a revised version of the cybersecurity rules that it first announced in the fall of last year. The rules apply to a wide range of insurance, banking, and...more

Back to the Future: 2017 [Expect Focus Life Insurance – December 2016]

- Should Your Company Purchase Bitcoin to Pay a Cyber Ransom? - NAIC Draws Line in CFPB Sandbox - NAIC’s Big Data Task Force Sets Charges for 2017 - Broker-Dealers Can Hold Customers’ Initial Checks...more

Although Delayed, New York's Aggressive Cybersecurity Law Expected to Affect Financial Services and Insurance Firms

The regulatory environment for cybersecurity is rapidly changing, and state legislatures are not waiting for Congress to act. On December 28, 2016, the New York State Department of Financial Services ("NYDFS") revised a...more

Peerless, This is Not: Sixth Circuit Finds No Latent Ambiguity in Consent to Settle Requirement in Excess Policy

Disputes between policyholders and excess insurers often involve events that occurred before the underlying defense costs or indemnity payments reached the excess layer. In Stryker Corp. v. Nat’l Union Fire Ins. Co. of...more

New York Department of Financial Services Revises Cybersecurity Proposal: Greater Flexibility and Delayed Compliance Deadlines

As we previously reported, in December 2016 the New York Department of Financial Services (the “DFS”) announced that it was revising its proposed regulation that would require banks, insurance companies and other financial...more

NAIC’s Big Data Task Force Sets Charges for 2017

The NAIC’s Market Regulation Committee recently adopted three broad charges developed by the Big Data Task Force. Formerly a "working group," the new "task force" designation reflects the entity’s more formalized and enduring...more

New York State Department of Financial Services Issues Updated Proposed Cybersecurity Regulation

The New York State Department of Financial Services (“DFS”) has updated its proposed regulation requiring banks, insurance companies, and other financial services institutions regulated by DFS to establish and maintain a...more

New York Department of Financial Services Cybersecurity Rules Revised and Delayed

The New York Department of Financial Services (NYDFS) just issued major revisions to the cybersecurity regulations for financial institutions that were due to come into effect on January 1, 2017. To allow covered institutions...more

New York Department of Financial Services Delays Compliance Deadline for Cybersecurity Regulations

On October 25, the Privacy Law Report featured a blog post on new cybersecurity regulations being implemented by the New York Department of Financial Services (“DFS”). Those regulations impose a number of requirements on...more

NYDFS Revises Cybersecurity Regulation, Extends Effective Date to March 1, 2017

The New York Department of Financial Services (NYDFS) announced today a revised regulation that will require all institutions subject to NYDFS supervision to establish and maintain a cybersecurity program meeting "certain...more

The Ghost of Systems Past: “Big Data” Suits Loom, But Old Data Issues Remain Unresolved

2017 could be big for litigation over “Big Data” applications in insurance. This past year saw the filing of several “price optimization” class actions, and claims against a fraud detection tool, similar to the ones used by...more

Lessons Learned in London

Earlier this month, I spent a week in the birthplace of D&O insurance, London. In addition to moderating a panel at Advisen’s European Executive Risks Insights Conference, I met with many energetic and talented D&O insurance...more

DFS Cyber Regulation: Changing the Rules – An Interview with Bay Dynamics’ Steven Grossman

As part of Patterson Belknap’s continuing focus on the New York Department of Financial Services (DFS) proposed cybersecurity regulation, we sat down with Steven Grossman, VP Strategy & Enablement at Bay Dynamics, a cyber...more

Law Firms and Vendors Mandated to Up Their Cyber Game: Final Installment in a 3-Part Series

This is our final installment in a three-part series examining the New York State Department of Financial Services (“DFS”) new cybersecurity regulation.  In this installment, we provide an overview of the regulation’s impact...more

New York Department of Financial Services Proposes Cybersecurity Regulation

On September 13, 2016, New York Governor Andrew Cuomo announced that the New York Department of Financial Services (the “DFS”) proposed a regulation that would require banks, insurance companies, and other financial services...more

Data Breach Decision Points: Part 5

The best way for a company to handle a data breach is to be prepared. As we discuss in our data breach readiness handbook, preparation includes, among other things, drafting an incident response plan, reviewing...more

FIO Annual Report On The Insurance Industry

In September, the Federal Insurance Office (“FIO”) issued its Annual Report on the Insurance Industry for 2015, including its “outlook” for 2016 based upon results reported through June 30, 2016....more

Ninety-Nine Problems but a Breach Ain’t One: Cybersecurity Lessons for Insurers

In the movie WallStreet , the character Gordon Gekko famously states that information is the most valuable commodity he knows. These days, the same could be said of data, which can now be bought, sold, and, increasingly,...more

Recent CyberSecurity Incidents Emphasize Importance of Cyberinsurance

As the threat of cyberattacks continues to pose daily threats to businesses large and small, more companies have turned to cyber insurance products to shore up protection against these disruptive threats. A spate of recent...more

What You Must Know about New York’s Proposed Cybersecurity Regulation for the Banking, Insurance, and Financial Services Sectors

Recently, New York’s Department of Financial Services released its long-awaited proposed cybersecurity regulation, which promises to deliver sweeping protections to consumers and financial institutions alike. The proposed...more

New York Department of Financial Services Proposes Comprehensive Cybersecurity Regulations for Financial Institutions

In September, the New York Department of Financial Services (“DFS”) proposed new rules (“Rules”) that would require covered financial institutions – banks, insurers, and other institutions regulated by the DFS – to establish...more

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