Department of Financial Services

News & Analysis as of

NY Financial Services Companies’ 2017 Resolution: Cybersecurity

The New York State Department of Financial Services (DFS) made headlines back in late September with a “first-in-the-nation” piece of legislation aimed at mandating specific cybersecurity protocols for banks, insurance...more

DFS Cyber Regulation: Part II – An Interview with Bay Dynamics’ Steven Grossman

This is the second installment in our interview with Steven Grossman, VP Strategy & Enablement at Bay Dynamics, the cyber risk analytics company. Here, Steven discusses the importance of aligning an institution’s risk...more

Financial Regulatory Developments Focus - November 2016

In this newsletter, we provide a snapshot of the principal US, European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset managers and...more

New York and Feds Leading the Charge on Financial Institution Cybersecurity Regulations

Both federal and state officials recently proposed new regulations aimed at the financial sector in an effort to promote protection against high-impact technology failures and cyberattacks...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

Cyber Regulation Demands Board Accountability: Part 2 in a 3-Part Series

This is our second 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

Unpacking New York’s Cybersecurity Regulation: Part 1 in a 3-Part Series

This is the first installment in a three-part series examining the New York State Department of Financial Services (“DFS”) new cybersecurity regulation. The Patterson Belknap Privacy and Data Security Team has studied the...more

Regulators Diverge on How Best to Manage Growing Cybersecurity Risks

On October 19, the Federal Reserve Board, Federal Deposit Insurance Corporation, and Office of the Comptroller of the Currency (the Agencies) issued an advance notice of proposed rulemaking (ANPR) seeking to enhance cyber...more

FinCEN Issues Advisory on the Reporting of Cyber-Events and Cyber-Enabled Crimes

The Financial Crimes Enforcement Network, or FinCEN, an arm of the United States Department of the Treasury, issued an advisory last week to remind financial institutions of their obligations to report cyber-events on...more

Cyber in the Board Room: Balancing Risk and Oversight

Boards of directors remain increasingly exposed to the threat of liability arising from data breaches and other cyber-incidents. Nearly a year ago, Senators Jack Reed and Susan Collins introduced the Cybersecurity...more

NYS Cyber Crack Down Looms: What Every Financial Institution, Insurer and Their Board Must Know

With the public comment period closing in a few days, the New York Department of Financial Services (DFS) “first in the nation” cybersecurity regulation is one step closer to becoming law. The regulation – which covers a...more

Cybersecurity Requirements Proposed for New York Financial Companies

The New York Department of Financial Services has proposed new cybersecurity regulations “designed to promote the protection of customer information as well as the information technology systems of regulated entities...more

New York's New Cybersecurity Rules: What Is Required?

The new cybersecurity rules proposed by the New York State Department of Financial Services require financial services institutions to have extensive cybersecurity protections in place; including cybersecurity programs,...more

In Case You Missed It - Interesting Items for Corporate Counsel - October 2016

After a one-month hiatus, we find ourselves with much to catch up on. Brace yourself. The SEC . . . - announced, that it no longer requires Tandy language, generally an acknowledgment in SEC comment...more

New York Department of Financial Services Proposes New Rules on Cybersecurity: The Organizational and Operational Impact

The New York Department of Financial Services (DFS) has proposed new rules that would require covered financial institutions to establish and maintain cybersecurity programs designed to protect customers, the financial...more

New York’s Proposed Cybersecurity Regulations Impose New Compliance Requirements on Financial Institutions and Insurance Companies

The New York State Department of Financial Services (NYSDFS) recently proposed new cybersecurity regulations for banks, insurance companies, and other financial institutions—the first regulations of their kind in the United...more

New York State Department of Financial Services Proposes Far-Reaching Cybersecurity Rules

The New York State Department of Financial Services (the DFS) has issued a proposed regulation that would impose cybersecurity-related requirements on entities it supervises. In some cases, these requirements would go beyond...more

New York's DFS Proposed Cybersecurity Regulations for Financial Institutions

New York's Department of Financial Services (DFS) has a proposed broad-reaching cybersecurity regulation that would impose new corporate governance, risk management and vendor management requirements on banks and other...more

New York DFS Promulgates Cybersecurity Requirements for Financial Services

The New York State Department of Financial Services promulgated proposed cyber security requirements to respond to “the ever-growing threat posed to information and financial systems by nation-states, terrorist organizations...more

New York DFS Announces New Proposed Cybersecurity Regulations

On September 13, 2016, the New York State Department of Financial Services (“DFS”) released proposed cybersecurity regulations for financial institutions.1 When the regulations become effective, they will make New York the...more

New York Regulators Propose Stricter Cybersecurity Rules

On September 13, 2016, New York Governor Andrew Cuomo proposed first-of-their-kind rules that would require financial institutions to develop and implement detailed cybersecurity programs. The proposed rules would apply only...more

New York State Department of Financial Services Proposes Cybersecurity Regulations for Financial Services Companies

If the New York State Department of Financial Services (“DFS”) has its way, come January 1, 2017, financial services companies that require a form of authorization to operate under the banking, insurance, or financial...more

New York Raises the Bar – Will Other States Follow?

On September 13, 2016, the New York Department of Financial Services (DFS) proposed new first-in-the-nation cybersecurity regulations (Regulations) that would require banks and other financial institutions to adopt minimum...more

New York DFS Proposes New Cybersecurity Regulations

Earlier this month, the New York State Department of Financial Services (“DFS”) announced proposed cybersecurity regulations for financial institutions. This proposal is, according to Governor Cuomo, a “new...more

A Proposed New York State Regulation Requires First-Of-Their-Kind Cybersecurity Requirements for Financial Services Companies

On September 13, 2016, New York Governor Andrew Cuomo announced that a first-of-its kind cybersecurity regulation has been proposed by the New York State Department of Financial Services (DFS) to further protect New York...more

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