News & Analysis as of

NYDFS

Herbert Smith Freehills Kramer

US Corporate Governance — 2025 Midyear Review

The Financial Crimes Enforcement Network (FinCEN) issued an interim final rule in March 2025 that removes requirements for US companies to report beneficial ownership information under the Corporate Transparency Act (CTA)....more

Alston & Bird

NYDFS Issues Guidance on Heightened Cybersecurity and Sanctions Risk from Global Conflict

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Overview - On June 23, 2025, the New York State Department of Financial Services (“NYDFS”) issued an industry letter encouraging all regulated entities to review their cybersecurity and sanctions compliance programs in light...more

Troutman Pepper Locke

NYDFS Warns of Heightened Risk From Global Conflicts: What Regulated Entities Must Do Now

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On June 23, the New York State Department of Financial Services (NYDFS) issued an industry letter to all regulated entities — banks, insurers, money transmitters, virtual currency companies, and others — cautioning that...more

Paul Hastings LLP

NYDFS Urges Covered Entities to Review Security Practices Amidst World Turmoil

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Citing “escalating global conflict,” the New York Department of Financial Services issued an alert on Monday, June 22, 2025, to its regulated covered entities, urging them to be vigilant against potential security threats,...more

Husch Blackwell LLP

Five Things to Know About the New York Buy-Now-Pay-Later Act

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As part of an omnibus 2026 budget bill, New York passed a new law that will broadly govern point-of-sale (POS) installment financing offered to New York residents. The Buy-Now-Pay-Later (BNPL) Act was signed into law in early...more

Bressler, Amery & Ross, P.C.

NY Department of Financial Services Issues Guidance to its Regulated Industry As a Result of the Ongoing Global Conflict

The New York State Department of Financial Services (the “Department”) has issued guidance (“Guidance”) to all individuals and entities regulated by the Department (“Regulated Entities”) to underscore the importance of...more

Sheppard Mullin Richter & Hampton LLP

NYC Comptroller Report Calls for Overhaul of State Consumer Financial Protections

On June 9, 2025, New York City Comptroller Brad Lander released a report urging City and State leaders to modernize consumer financial protections. The report outlines a series of legislative and regulatory recommendations...more

Cadwalader, Wickersham & Taft LLP

Digital Assets-Focused UCC Amendments Pass New York Legislature

On June 11, 2025, the New York State Senate passed a bill adopting the 2022 Amendments to the Uniform Commercial Code (UCC). The 2022 Amendments have now been passed by both houses of the New York legislature, and can be...more

Orrick, Herrington & Sutcliffe LLP

New York publishes a report highlighting areas to strengthen consumer financial laws

On June 9, New York City Comptroller Brad Lander issued a report highlighting the ways in which New York State policymakers can strengthen consumer financial protections for New York citizens. Specifically, the report...more

Cadwalader, Wickersham & Taft LLP

Heating Up, June 2025 - 2022 Amendments Pass Both Houses of NY Legislature

Breaking news out of the New York legislature that they have passed the 2022 Amendments to the Uniform Commercial Code (UCC). The amendments would now go to the governor....more

Blank Rome LLP

Executive Summary – New York Regulation and Disclosure – What Mortgage Applicants Need to Know

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A new law in New York took effect on June 11, 2025, requiring banking organizations, licensed lenders, and mortgage bankers provide a disclosure pamphlet titled “What Mortgage Applicants Need to Know” (the “Pamphlet”)....more

BakerHostetler

Weekly Blockchain Blog - June 2025 #2

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Crypto Payments Companies Achieve Licenses, Enhance Product Offerings - A U.S. digital asset payments company, MoonPay, recently announced that it has been granted a BitLicense by the New York Department of Financial...more

Weber Gallagher Simpson Stapleton Fires &...

The Legal Landscape of AI in Insurance: What New York Insurers Need to Know

This update provides an overview of the legal and regulatory considerations surrounding the use of artificial intelligence (AI) products and New York law in insurance products; with a particular focus on underwriting,...more

Orrick, Herrington & Sutcliffe LLP

New York governor announces financial services updates for state

On May 9, New York Governor Kathy Hochul announced several updates related to financial services for the State of New York. Hochul announced new legislation as part of the FY26 enacted budget to regulate “Buy Now, Pay Later”...more

Fisher Phillips

New Cyber Rules in Effect as of May 1 for NY Financial Firms: 3 Key Compliance Priorities

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New cybersecurity requirements just kicked in for thousands of financial firms operating in New York, and companies need to make sure they have taken action to comply. As of May 1, the latest amendments to the New York...more

Eversheds Sutherland (US) LLP

Recent Executive Order on disparate impact: what it means for insurer’s use of AI

On April 23, 2025, President Donald Trump issued an Executive Order titled “Restoring Equality of Opportunity and Meritocracy” (order). The order declares disparate impact theory to be “wholly inconsistent with the...more

Hogan Lovells

NYDFS: Penultimate set of cybersecurity requirements under amended Part 500 take effect May 1, 2025

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On May 1, 2025, additional cybersecurity requirements introduced by the Second Amendment to the New York Department of Financial Services (NYDFS) Cybersecurity Regulation (23 NYCRR Part 500) (the “Second Amendment”) took...more

Hudson Cook, LLP

State Watch: Consumer Protection Enforcement Update

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While uncertainty continued to loom over the CFPB, the states did not take a spring break. Instead, we saw an eye-popping settlement from NY DFS involving BSA/AML claims. And both republican and democratic AGs continued to...more

Skadden, Arps, Slate, Meagher & Flom LLP

Cybersecurity Trends in the Digital Asset Space

After years of regulatory uncertainty, the Trump administration has signaled a new approach to digital assets, including by establishing a working group focused on digital assets and nominating crypto-friendly chairs to the...more

Alston & Bird

Additional Cybersecurity Requirements of NYDFS Part 500 Take Effect

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On May 1, 2025, additional enhanced cybersecurity controls required by the Second Amendment to the New York Department of Financial Services (NYDFS) Cybersecurity Regulation (23 NYCRR Part 500) (the “Second Amendment”) take...more

Husch Blackwell LLP

Effective Dates Draw Near for Insurance Industry to Comply with NYDFS's Cybersecurity Rules

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As part of a multiyear rollout, the New York Department of Financial Services (NYDFS) has established May 1, 2025, and November 1, 2025, as effective dates for certain amendments to its cybersecurity regulations. These...more

Alston & Bird

Cybersecurity Controls: What Do Regulators Expect Nowadays?

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Our Privacy, Cyber & Data Strategy Team highlights the increasingly specific cybersecurity controls identified by regulators, explains why these enhanced cybersecurity controls have become the focus of regulators, and shares...more

Hinshaw & Culbertson - Privacy, Cyber & AI...

Are Your Cybersecurity Controls Ready for the New York State Department of Financial Services' Deadlines?

In November 2023, New York State's Department of Financial Services (NYDFS) amended its cybersecurity regulation, Part 500. This legal alert provides an update for Covered Entities and Class A Businesses on the current NYDFS...more

BakerHostetler

Weekly Blockchain Blog - April 2025 #2

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Digital Asset Companies Announce New Partnerships, Acquisitions, Products - A recent press release announced that Ripple, a U.S. fintech and digital asset infrastructure provider, has agreed to acquire Hidden Road, a prime...more

Sheppard Mullin Richter & Hampton LLP

NYDFS Joins Multistate Action Against Money Transmitter for Financial and Licensing Violations

On March 20, the New York Department of Financial Services (NYDFS) entered into a consent order with a money transmitter, joining a group of state financial regulators acting through a multi-state task force coordinated by...more

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