Covered Entities

News & Analysis as of

New York Cybersecurity Regulations: What Do They Mean and When Do They Mean it By?

The New York State Department of Financial Services (NYDFS) has released guidance for covered financial institutions regarding its cybersecurity rule (the “Cybersecurity Rule” or “Rule”) that took effect on March 1, 2017. ...more

340B Program Ceiling Price and CMP Final Rule Delayed Until May 22

On 20 March 2017, the Health Resources and Services Administration (HRSA) published an Interim Final Rule (IFR) delaying the effective date of the 340B Ceiling Price and Civil Monetary Penalties (CMP) Rule (the Final Rule)...more

HIPAA Checkup – How Good Are Your Policies and Procedures?

Although it is not a new requirement, it is important and therefore worth a reminder: HIPAA requires covered entities to establish and implement written policies and procedures that are consistent with its Privacy and...more

NYDFS Cybersecurity Regulations Compliance Guide: Applicability, Exemptions and Penalties

As discussed in our March 1, 2017 update,1 the New York Department of Financial Services ("NYDFS") issued final regulations that require New York banks and insurance companies, as well as other financial services companies...more

NY DFS Publishes Final Cybersecurity Rules for Financial Services Companies 

On March 1, 2017, the New York Department of Financial Services (the DFS) published a notice of adoption of its final cybersecurity regulation (the Final Regulation). The regulation was first announced with much fanfare by...more

New York Department of Financial Services Implements New “First-in-the-Nation” Cybersecurity Regulations

As of March 1, 2017, New York financial institutions subject to the oversight of the New York Department of Financial Services (“DFS”) are required to comply with a new cybersecurity regulatory scheme. Compliance deadlines...more

Trio of Bills Would Impose Human Trafficking Obligations on Lodging Industry

A trio of bills introduced recently in the California Legislature seek to involve the lodging industry in efforts to combat human trafficking. Assembly Bill 260 by Assemblymember Miguel Santiago (D-Los Angeles) would...more

New York Department of Financial Services Cybersecurity Regulations Take Effect | Publications

PDF Version New cybersecurity-related regulations issued by New York state regulators took effect March 1, 2017. The rules, which directly impact all entities regulated by the New York Department of Financial Services (such...more

New York DFS Finalized Cybersecurity Regulations Go Into Effect March 1, 2017

On February 16, 2017, the New York State Department of Financial Services (DFS) announced the final version of the “first-of-its-kind” cybersecurity regulations governing financial institutions, insurance companies, and other...more

New York's Far-Reaching Cybersecurity Law Takes Effect March 1 - Are You Ready?

New York’s Department of Financial Services Cybersecurity regulation became effective March 1. According to the press release issued with the regulation, the regulation is intended to require banks, insurance companies and...more

Cybersecurity and Data Privacy: Department of Financial Services Issues Final Cybersecurity Regulations With Broad Implications...

On February 16, 2017, the New York State Department of Financial Services ("DFS") issued final cybersecurity regulations, with extensive new requirements for cybersecurity programs by entities regulated by DFS ("Covered...more

NYS Department of Financial Services Cybersecurity Regulation Goes Live: Now What?

March 1, 2017 marks the effective date of the New York State Department of Financial Services (NYDFS) Cybersecurity Requirements for Financial Services Companies (the Rules). We previously reported on these emerging standards...more

2017 HIPAA Enforcement: Year to Date Lessons

With the announcements from OCR of three resolution agreements and one civil money penalty as of mid-February, OCR is off to a record start for HIPAA enforcement in 2017, with double the announcements as the same time last...more

Sweeping New York Cyber Regulations Hit Financial Institutions March 1: Time to Look at Those Vendor Relationships

Effective March 1, 2017, first-in-kind regulations issued by the New York Department of Financial Services (New York DFS) will begin to affect a wide array of both depository and non-depository financial institutions. The new...more

New York State Department of Financial Services Issues Final Cybersecurity Regulations

On February 16, 2017, the New York State Department of Financial Services ("DFS") issued final cybersecurity regulations (the "Final Regulations"), with extensive requirements for cybersecurity programs by entities regulated...more

Finalized New York Department of Financial Services Cybersecurity Regulation to Take Effect March 1

On February 16, 2017, the New York Department of Financial Services (NYDFS) announced the release of its finalized Cybersecurity Requirements for Financial Services Companies (“Cybersecurity Regulation”), which will take...more

Orrick's Financial Industry Week In Review

Financial Industry Developments - New York Department of Financial Services Promulgates First-in-the-Nation State Cybersecurity Regulation - On February 16, 2017, the New York Department of Financial Institutions...more

One of a Kind: NYDFS Cyber Rule Finalized, Effective March 1, 2017

The closely watched New York State Department of Financial Services (NYDFS) cybersecurity standards for covered financial institutions are now final and take effect March 1, 2017 in less than a week. The final rule largely...more

NYDFS announces final cybersecurity rules for financial services sector: key takeaways

On February 16, 2017, Governor Andrew Cuomo announced final cybersecurity rules for New York’s financial services sector. The Cybersecurity Requirements For Financial Services Companies (the Final Rule), promulgated by the...more

New York Finalizes Cybersecurity Regulations for Financial Institutions

On February 16, the New York State Department of Financial Services (NYDFS) issued cybersecurity regulations for banks, insurance companies and other financial institutions subject to NYDFS jurisdiction. ...more

New York Department of Financial Services Promulgates First-in-the-Nation State Cybersecurity Regulation

On February 16, 2017, the New York Department of Financial Institutions (“DFS“) promulgated a regulation that requires “Covered Entities” to establish and maintain a cybersecurity program designed to protect consumers and the...more

340B Drug Pricing Program: The Withdrawal of Mega Guidance and the Future of Patient Definition

In the wake of a recent directive issued by the Trump administration to halt pending regulations and guidance while the new leadership conducts its own review, the Department of Health and Human Services, on January 30, 2017,...more

HIPAA for HR - Some Good News for Employers

The Health Insurance Portability and Accountability Act of 1996 (HIPAA) is a federal law that was enacted to ensure protection of individuals’ protected health information (PHI). The Standards for Privacy of Individually...more

HIPAA Enforcement Update (October 2016 – January 2017)

Since October 2016, the Department of Health and Human Services, Office for Civil Rights (OCR) announced four settlement agreements to resolve allegations of Health Insurance Portability and Accountability Act (HIPAA)...more

HIPAA Small Breach Notification Due March 1: “In Like a Lion, Out Like a Lamb” if You Submit Timely

March 1, 2017 is the date by which HIPAA covered entities must notify the U.S. Department of Health and Human Services Office for Civil Rights (OCR) of “small” breaches of unsecured protected health information that were...more

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Cybersecurity

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