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Let’s role-play the title “Chief Information Security Officer” (CISO) as various chess pieces, each representing different aspects of the challenges and responsibilities faced in this critical position. Examining these...more
RegFi co-hosts Jerry Buckley and Sherry Safchuk welcome Orrick partner Aravind Swaminathan for a conversation exploring the critical and evolving role of the Chief Information Security Officer in today’s corporate landscape.....more
A major amendment to the New York State Department of Financial Services' cybersecurity regulations establishes affirmative cybersecurity oversight duties and requires companies to report extortion payments to the agency....more
On October 27, 2021 the FTC issued a final rule (the “Final Rule”) amending 16 CFR Part 134, Standards for Safeguarding Customer Information (“Safeguards Rule”), after a period of notice and comment. While the existing...more
The New York Department of Financial Services (NYDFS) has launched its first enforcement action under New York’s Cybersecurity law for financial services, so-called Part 500. Part 500 requires NYDFS licensed institutions to...more
Developing Contingency Plans: The NYDFS Mandate on Licensed Virtual Currency Businesses - The events surrounding COVID-19 have increased the use of fintech products, both out of necessity and convenience. Shelter-in-place...more
The NYDFS has announced that it has extended the deadline for compliance with certain cybersecurity requirements due to the coronavirus emergency. The announcement from the Superintendent of Financial Services of the State...more
The one-year transitional period under the New York Department of Financial Services (NYDFS) Cybersecurity Requirements for Financial Services Companies expired on March 1, 2018. Financial services companies that are...more
It’s been almost a year since the New York State Department of Financial Services (NYDFS) Cybersecurity Regulation (23 NYCRR Part 500) came into effect. Since that time, a series of key dates have marked the implementation of...more
As we reported here, March 1, 2018 brings a new transition date, with a new set of compliance obligations for Covered Entities subject to the Cybersecurity Regulation of the New York Department of Financial Services. By...more
The state of New York’s Department of Financial Services (DFS) issued the first state-level regulations on cybersecurity for financial institutions with its Cybersecurity Requirements for Financial Services Companies release,...more
The New York Department of Financial Services has new cybersecurity regulations “designed to promote the protection of customer information as well as the information technology systems of regulated entities [financial...more
We have previously reported about the upcoming New York Financial Services Cybersecurity Regulations. On February 16, 2017, Governor Andrew M. Cuomo announced that “the first-in the-nation cybersecurity regulation to protect...more
As Hogan Lovells previously reported, the New York State Department of Financial Services (NYDFS) has launched a significant initiative to impose detailed cybersecurity requirements on covered financial institutions. On...more
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
A covered entity will need to arrange for someone to perform the CISO function, dedicate resources to conduct periodic risk assessments, develop and implement policies and procedures, and retain appropriate personnel and...more
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
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
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