NY DFS Cybersecurity Exemption Filings due October 30

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October 30, 2017 is the extended deadline for most Covered Entities claiming an exemption to file the Notice of Exemption required by the NY DFS Cybersecurity Regulation (23 NYCRR 500.19(e)).  The filing deadline is 30 days after a Covered Entity has determined that an exemption applies.  Therefore, for Covered Entities determining one of most of the available exemptions (23 NYCRR 500.19(a)-(d)) applies on or before October 1, 2017, the deadline is October 30.

Covered Entities with 50 or more employees, agents, representatives, or designees who are (i) also Covered Entities (because they are individually licensed by the DFS), (ii) covered by the Information Security Program of the Covered Entity, and (iii) all qualified by the same exemption, can request permission from DFS to file a batch exemption on their behalf.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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