News & Analysis as of

NYDFS

Equifax: The Empire State Strikes Back

Yesterday, New York Governor Andrew M. Cuomo announced that he has directed the Department of Financial Services (DFS) to issue a new regulation requiring “credit reporting agencies to register with” the DFS, as well as...more

Equifax Data Suppliers Urged by DFS to Give Hack “Highest Degree of Attention”

Yesterday, New York’s top financial regulator asked state-chartered banks and insurers to take immediate precautions to protect consumers and the financial markets “in light of the cybersecurity attack” at Equifax Inc....more

Orrick's Financial Industry Week In Review

CFPB Issues Final Rule Temporarily Raising Reporting Threshold for Home Equity Loans Under Home Mortgage Act Rules - On August 24, 2017, the Consumer Financial Protection Bureau (the "CFPB") issued a new rule that amends...more

Compliance with Initial New York DFS Cybersecurity Rules Now Mandatory

As of August 28, 2017, insurance companies, banks, and other financial services companies regulated by the New York Department of Financial Services (“DFS”) must comply with an initial wave of new cybersecurity requirements...more

NY DFS Charges the NY Branch of Habib Bank and Habib Bank Limited for Compliance Failures

On August 24, 2017, the New York State Department of Financial Services (“NY DFS“) issued a Notice of Hearing and Statement of Charges to the New York Branch of Habib Bank Limited and Habib Bank Limited, the largest bank in...more

New York Proposes Regulation to Amend Form A Process

by Locke Lord LLP on

Last month, the New York Department of Financial Services (“NYDFS”) proposed an amendment to 11 NYCRR 80-1.6 (the “Regulation”), which would augment the application process to acquire a domestic insurer by potentially...more

NAIC Cybersecurity Progress

by Locke Lord LLP on

On August 7, 2017, the NAIC’s Cybersecurity (EX) Working Group met in its continuing effort to develop a model cybersecurity law for the insurance industry. This effort, which commenced over a year ago, has taken a new...more

Object Lesson on How Not to Respond to Consent and Enforcement Actions

by Sullivan & Worcester on

Last week, the DFS announced an enforcement action and charges against the NY Branch of Habib Bank, a Pakistani bank that had been doing business in NY for almost 40 years....more

New York DFS Cyber Rules Go Live: Here’s Your Roadmap

by Orrick - Trust Anchor on

August 28, 2017 marks the end of the initial 180-day grace period for compliance under the New York Department of Financial Services’ “first-in-the-nation” cybersecurity regulations (the “Rules”). The initial regulations...more

NAIC Insurance Data Security Model Law Poised for Adoption

On August 7, 2017, the National Association of Insurance Commissioners (“NAIC”) Cybersecurity Working Group adopted as final, over one dissenting vote, the sixth draft of the NAIC Data Security Model Law. The next day, the...more

NYDFS proposed regulation addresses financial disclosure requirements for directors and officers of private equity buyers of...

by Hogan Lovells on

On August 9, 2017, the New York Department of Financial Services (NYDFS) released for public comment proposed amendments to its regulations governing the approval process for the acquisition of control of insurance companies...more

First Compliance Hurdle For New York Department Of Financial Services Cybersecurity Regulations Due August 28

by Jackson Lewis P.C. on

The New York State Department of Financial Services (DFS) has set cybersecurity regulations that require minimum standards for protecting the customer information and information systems of the financial services industry....more

Timeline For Compliance With New DFS Cybersecurity Regulations

by Jackson Lewis P.C. on

The deadline to comply with the first set of requirements under the new DFS Cybersecurity Regulations (“the Regulations”) is here! By today, August 28, 2017, businesses subject to the Regulations must ensure that...more

Window on Washington - This Week in the Nation's Capital - Vol. 1, Issue 23

by Clark Hill PLC on

CBO Confirms Size of Breach of Defense Cap for FY18 Bills: The House FY18 Omnibus Appropriations Bill scheduled to be taken up in September would bust the Defense cap by $72 billion. This would cause the Office of Management...more

OCC moves to dismiss NYDFS lawsuit challenging special purpose national bank charter for fintech companies

by Ballard Spahr LLP on

The Office of the Comptroller of the Currency (OCC) has filed a motion to dismiss the lawsuit filed by the New York Department of Financial Services (DFS) challenging the OCC’s authority to grant special purpose national bank...more

Deadline to Meet DFS Cyber Regulation Is Monday

Banks, insurance companies and other financial institutions have only a few days left to comply with the first wave of requirements under New York’s controversial new cybersecurity regulation....more

NYSDFS Upcoming Deadline Fast Approaching: First Key Date is August 28, 2017

by Shipman & Goodwin LLP on

On March 1, 2017, the New York State Department of Financial Services’ (“DFS”) first-in-nation Cybersecurity Regulations for the purpose of protecting consumers and financial institutions from cyber-attacks went into effect...more

New York State Cybersecurity Regulations: First milestone in sight, what is next on the horizon?

by Shearman & Sterling LLP on

The New York State Department of Financial Services (“NYDFS”) enacted final cybersecurity regulations (“Regulations”) for NYDFS regulated entities that went into effect on March 1, 2017. The first deadline for compliance...more

Deadline to Comply with New York's Cybersecurity Regulation Is Approaching

by Jones Day on

For entities regulated by the New York Department of Financial Services, the deadline for complying with the new Cybersecurity Requirements for Financial Services Companies, 23 NYCRR Part 500, is Monday, August 28, 2017. To...more

NAIC Takes Major Step Toward Final Approval of Insurance Data Security Model Law

In a flurry of approvals last week, the National Association of Insurance Commissioners (NAIC) took substantial steps toward finalizing its proposed Insurance Data Security Model Law during the 2017 NAIC Summer National...more

Combating climate change: NYDFS calls on insurance industry to help

by Hogan Lovells on

On 26 July 2017, the New York Department of Financial Services (the “NYDFS”) issued Circular Letter No. 9 (2017) (the “Circular Letter”) and a corresponding press release, directed at all life, property/casualty, and health...more

NY Cybersecurity Regulations for Financial Services Companies: Enforcement Begins Aug. 28

by McGuireWoods LLP on

August 17, 2017 The 180-day transitional period under the New York Department of Financial Services (NYDFS) Cybersecurity Requirements for Financial Services Companies is set to expire Aug. 28, 2017. Financial services...more

Blockchain's Steady March to Legitimacy

by White & Case LLP on

Four separate events during the second half of July signal that virtual currency and blockchain are steadily becoming part of mainstream financial services. The interconnected histories of Bitcoin (the most common virtual...more

Are You Ready for the New York August 28th Compliance Deadline?  

If you are one of the many businesses licensed by the New York Department of Financial Services (DFS), and cannot avail yourself of the (very) limited exemptions, you must be ready for the first compliance transition date for...more

DFS Cyber Regulation Countdown: Who Should Certify Compliance?

Companies subject to New York’s Department of Financial Services (DFS) new cybersecurity regulation should be preparing to comply with the first round of requirements by the upcoming August 28th deadline: enacting a...more

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Cybersecurity

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