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Change Healthcare Inc. has amended its initial breach report to the HHS Office for Civil Rights (OCR) to state that 100 million individuals were impacted by its mammoth ransomware attack and breach. However, as of Oct. 24,...more
In July, Connecticut passed a largely unnoticed new law that followed in the footsteps of Ohio and Utah in limiting damages or creating affirmative defenses for business that experience a data breach after implementing a...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 Ohio legislature recently passed S.B. 220, which gives businesses that suffer a data breach an affirmative defense against tort claims brought in class action suits....more
A new bill introduced by House Financial Services subcommittee Chairman Rep. Blaine Luetkemeyer would significantly change data security and breach notification standards for the financial services and insurance industries. ...more
We reported last week that a spyware maker recently compromised users’ and victims’ sensitive information. Since that time, another spyware maker, mSpy, which holds itself out as having over a million users employing its...more
The New York State Department of Financial Services (NYDFS) Cybersecurity Regulation (23 NYCRR Part 500) came into effect March 1, 2017...more
Last month, the New York State Department of Financial Services (NYDFS) proclaimed, “In an era of weakened federal government oversight, strong state regulation is essential in order to safeguard our markets, ensure strong...more
For the several thousand financial institutions and insurance companies covered by New York’s landmark data security regulation, the first certification of compliance must be filed with the State’s Department of Financial...more
On February 15th, organizations subject to the New York Department of Financial Services Cybersecurity Regulation are required to submit their first annual certification attesting to their compliance with the state’s new data...more
I travel around helping businesses, both large and small, work on assessing their cybersecurity risks and implement measures to protect data, reduce risk and comply with applicable state and federal laws. In doing so, it is...more
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
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
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
As a follow-up to our previous reports (December 30, 2016 Alert; February 24, 2017 Alert) regarding the cybersecurity regulations issued by the New York State Department of Financial Services (NYDFS), we would like to remind...more
Effective March 1, 2017, the New York State Department of Financial Services promulgated regulations to help protect against cybercriminals and their efforts to exploit sensitive electronic data. These cybersecurity...more
The New York Department of Financial Services (NYDFS) recently updated frequently asked questions (FAQs) about its cybersecurity regulations, 23 NYCRR 500, to address four new issues. NYDFS published its initial set of FAQs...more
New York’s powerful Department of Financial Services (DFS) upended cybersecurity regulation with its new and sweeping “Cybersecurity Requirements for Financial Services Companies,” which took effect on March 1, 2017. But is...more
A new survey by the Ponemon Institute reports that less than half of the financial institutions covered by New York’s sweeping new cybersecurity regulation say they will “likely” meet next February’s compliance deadline. And...more
On December 28, 2016, the New York Department of Financial Services ("DFS") released a revised version of a proposed regulation that would require banks, insurance companies, and other financial services institutions...more
The New York Department of Financial Services (“DFS”) recently released the much-anticipated final version of its “first-in-nation” cybersecurity rules that it first announced in the fall of last year. The rules require a...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