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NYDFS

Pillsbury Winthrop Shaw Pittman LLP

New York DFS Fines Delta Dental $2.25 Million for Cybersecurity Rule Violations

On April 30, 2026, the New York State Department of Financial Services (DFS) announced a $2.25 million cybersecurity settlement with Delta Dental Insurance Company (DDIC) and Delta Dental of New York, Inc. (DDNY)...more

Sheppard

NYDFS Reaffirms State Fair Lending Obligations

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On April 22, the NYDFS issued an industry letter reminding entities regulated under the New York Banking Law of their obligations under Section 296-a of the New York Executive Law, New York’s fair lending statute. The letter...more

BakerHostetler

The New Era of Regulation S‑P: When Vendors Breach, the Clock Starts Ticking

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Even during times of change regarding regulatory priorities, regulators remain focused on cybersecurity, information governance and data privacy across the financial services sector. But in recent times, two priorities have...more

Davis Wright Tremaine LLP

New York Proposes Open Banking-Style Financial Data Access Legislation

Federal rulemaking implementing Section 1033 of the Consumer Financial Protection Act remains stalled by litigation over the legality of the Consumer Financial Protection Bureau's 2024 "open banking" final rulemaking and the...more

Orrick, Herrington & Sutcliffe LLP

NYDFS reiterates companies’ fair lending obligations under state banking laws

On April 22, NYDFS issued an industry letter to all entities regulated by the department under the New York Banking Law, outlining their obligations under New York’s fair lending law, N.Y. Executive Law § 296-a. The letter...more

Haynes Boone

2026 New York Insurance Academy Key Takeaways

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Below, you will find a recap and key takeaways.  Digital assets and blockchain are here to stay, and insurance carriers are eager to provide coverage to these emerging industries....more

Cooley LLP

Part 3: Looking Ahead – Novel Cybersecurity Issues and Department Priorities

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In prior posts, we discussed the amendments to 23 NYCRR Part 500 (Part 500) ahead of the April 15 deadline to certify compliance with Part 500 and the increasing focus on multifactor authentication (MFA) as a key...more

Davis Wright Tremaine LLP

NY Overhauls Transparency and Governance Requirements for Frontier AI Developers

New York Governor Kathy Hochul recently signed Senate Bill 8828, which overhauls the Responsible AI Safety and Education Act (RAISE Act). When Gov. Hochul signed the RAISE Act in December 2025, she issued an accompanying...more

Ballard Spahr LLP

Consumer Finance Monitor Podcast Draws Coverage from “Inside the CFPB”: A First for Our Platform

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In its April 6, 2026 issue, “Inside the CFPB,” a widely read subscription publication published by “Inside Mortgage Finance Publications” highlighted our recent podcast episode released on April 2, 2026 featuring discussion...more

Blank Rome LLP

New York Just Changed the Game for Buy Now, Pay Later

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New York became the first state to publish comprehensive regulations governing Buy Now, Pay Later (“BNPL”) financing on February 23, 2026, and the implications for retail finance are significant. The proposed rule implements...more

Cooley LLP

Part 2: NYDFS Sharpens Its Focus on Multifactor Authentication

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Financial institutions covered by 23 NYCRR Part 500 (Part 500) (covered entities) must annually certify their compliance with these cybersecurity regulations....more

Cooley LLP

NYDFS Refresher Series – Part 1: What Companies Need to Know Ahead of Annual Certifications of Compliance

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Every year by April 15, financial entities subject to the New York Department of Financial Services (NYDFS) oversight (covered entities) are required to certify their compliance with the NYDFS’ cybersecurity regulations, 23...more

McDermott Will & Schulte

New York proceeds with expansive regulation of buy now, pay later products

On February 23, 2026, the New York State Department of Financial Services (NYDFS) published a proposed regulation (the Proposed Regulation) implementing the state’s Buy Now, Pay Later (BNPL) Act, which was signed into law by...more

BakerHostetler

Weekly Blockchain Monitor - March 2026 #3

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Financial Institutions and Crypto Payments Companies Launch Products, Collaborations - A major U.S. financial institution that operates one of the world’s largest card payment networks recently announced its Crypto Partner...more

Mayer Brown

NYDFS Teases Extensive New BNPL Requirements in Pre-Proposal Rulemaking Activity

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New York’s pioneering Buy-Now/Pay-Later (“BNPL”) Law is one step closer to taking effect with the issuance of pre-proposed regulations by the state’s Department of Financial Services (“NYDFS”) on February 23, 2026....more

Holland & Knight LLP

From Statute to Supervision: Preparing for New York's New BNPL Regulatory Regime

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Gov. Kathy Hochul and the New York Department of Financial Services (DFS) on February 23, 2026, issued a Draft Proposal that would, for the first time, establish a comprehensive regulatory framework for buy-now-pay-later...more

Paul Hastings LLP

NYDFS Offers Suggestions on Multifactor Authentication Implementation

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The New York Department of Financial Services (NYDFS) held a webinar on Feb. 26 to provide guidance on the Part 500 Cybersecurity Regulation second amendment’s (Part 500) multifactor authentication (MFA) requirements that...more

Venable LLP

NYDFS Proposes Comprehensive Rules for Buy Now, Pay Later Lenders

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New York is moving to establish a dedicated licensing and consumer-protection regime for Buy Now, Pay Later (BNPL) products. The New York legislature enacted the Buy Now Pay Later Act (Article 14-B of the New York Banking...more

Orrick, Herrington & Sutcliffe LLP

NYDFS warns financial sector of heightened cyber threats amid global conflict

On March 3, NYDFS issued an industry letter warning regulated financial entities of heightened cybersecurity threats stemming from ongoing global conflicts. The department noted that while it had not observed signs of a...more

Alston & Bird

NYDFS Revises Prescriptive FAQs on Multifactor Authentication

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Two months after the New York Department of Financial Services (“NYDFS”) updated its Frequently Asked Questions (“FAQs”), which we wrote about here, NYDFS has released updated FAQs on multifactor authentication (“MFA”) that...more

Cooley LLP

New York Leads the Way on Buy Now, Pay Later Regulation

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New York has taken a significant step toward comprehensive regulation of buy now, pay later (BNPL) by requiring licensure and disclosures designed for credit cards, even though BNPL transactions are closed end....more

Orrick, Herrington & Sutcliffe LLP

New York Proposes Comprehensive BNPL Rule: What BNPL Providers Need to Know

On February 23, 2026, the New York State Department of Financial Services (DFS) proposed new regulations to implement the Buy-Now-Pay-Later Act enacted in May of last year. If adopted, the proposed rule would regulate the...more

Troutman Pepper Locke

NY DFS Hosts Webinar on MFA Requirements

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Under the revised NYDFS Cybersecurity Regulation, covered entities must implement and enforce MFA for all access to all information systems — not just adopt MFA tools — and carefully document any CISO-approved compensating...more

BCLP

New York's Proposed Regulations for Buy Now, Pay Later Consumer Finance Services

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Buy-now, pay-later plans have seen rapid and widespread popularity among consumers and retailers. Acting in a perceived regulatory vacuum at the federal level, New York has adopted legislation to protect consumers as part of...more

Ballard Spahr LLP

New York Publishes Buy Now, Pay Later Rules

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The New York Department of Financial Services has published proposed rules governing Buy Now, Pay Later (BNPL) financing plans operating in the state. ...more

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