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The New York Department of Financial Services (DFS) has been increasingly active in enforcing the rigorous cybersecurity requirements imposed on “covered entities” under 11 NYCRR Part 500 (Reg 500). DFS has published an...more
Yesterday, New York’s Department of Financial Services (“DFS”) announced another enforcement action under the state’s Cybersecurity Requirements for Financial Services Companies, 23 N.Y.C.R.R. Part 500 (“Reg 500”). According...more
Sometimes a comprehensive overview is needed to recognize that individual anomalous conduct is indicative of a criminal scheme. Recently, the Department of Financial Services (DFS) looked at an unusual pattern of interaction...more
On February 4, 2021, New York’s Department of Financial Services (DFS) issued Insurance Circular Letter No. 2, which builds on the robust cybersecurity regulation provided in its 2017 Cybersecurity Regulation (23 NYCRR 500)....more
The New York State Department of Financial Services (DFS) has issued guidance imposing rigorous cyber risk measurement and management practices on NY-regulated property/casualty insurers that write cyber insurance. The...more
Like most industries today, Consumer Finance Services businesses are being significantly impacted by the novel coronavirus (COVID-19). Troutman Pepper has developed a dedicated COVID-19 Resource Center to guide clients...more
Key Points - - For the first time, New York's top banking and insurance regulator filed an enforcement action under the New York State Department of Financial Services (DFS) Cybersecurity Regulation (the Regulation). - DFS'...more
On July 21, 2020, the New York Department of Financial Services (DFS) filed a “Statement of Charges and Notice of Hearing” (the “Charges”) against First American Title Insurance Company (the “Company”) alleging violations of...more
On March 10, 2020, the New York Department of Financial Services issued Insurance Circular Letter No. 5, titled “Guidance to Department of Financial Services Regulated Insurance Entities and Request for Assurance Relating to...more
NYDFS Extends Deadline to File Certificate of Compliance Under Cybersecurity Regulation in Light of COVID-19 Crisis Given the ongoing COVID-19 pandemic, the New York State Department of Financial Services (NYDFS) extended...more
In new alerts, both state and federal regulators are cautioning the financial services industry about heightened cybersecurity risk amid a climate of increased geopolitical tensions....more
In regulatory oversight news, the New York Department of Financial Services (DFS) announced the creation of a new Cybersecurity Division and the Financial Crimes Enforcement Network (FinCEN) launched an Innovation Hours...more
In this month's edition, we examine a judge's ruling allowing an investor suit against Equifax, the dismissal of a class action against the insurer CareFirst and President Donald Trump's launch of a federal artificial...more
In a recent letter, the New York Department of Financial Services provided guidance for insurers who use third party data to help with their underwriting decisions. The letter was drafted in response to reports that insurers...more
Tuesday, September 4, 2018 marked the New York State Department for Financial Service’s deadline for compliance with several sections of cybersecurity regulation 23 NYCRR 500 (the “Regulation”). The Regulation covers any...more
New York Governor Andrew Cuomo has issued a final regulation that requires credit reporting agencies doing business in New York to register annually with the Department of Financial Services (DFS) and also to comply with...more
Hoping to help covered entities, the Securities and Exchange Commission (SEC) released an update on cybersecurity while New York’s Department of Financial Services (DFS) published guidance for licensed virtual currency...more
In this month's edition of our Privacy & Cybersecurity Update, we examine the Identity Theft Research Center's findings on data breaches in 2017, the U.S. Supreme Court's denial of certiorari that leaves in place the circuit...more
The time has come for entities regulated by the New York Department of Financial Services to make their first certification of compliance with the regulator’s cybersecurity rules....more
The New York Department of Financial Services' (DFS) cybersecurity regulation (DFS Regulation), which took effect on March 1, 2017, imposes significant requirements on financial services companies doing business in New York....more
Financial institutions covered by the New York State Department of Financial Services’ (NYDFS) new Cybersecurity Requirements for Financial Services Companies must file their first annual certification by February 15, 2018....more
• NAIC recently adopted an Insurance Data Security Model Law that follows the risk assessment-based approach of the New York DFS Cybersecurity Regulation. This signals the growing influence of the New York Regulation,...more
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 they: ...more
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
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