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On October 2, 2024, New York adopted new regulations requiring general hospitals to implement heightened cybersecurity safeguards. General hospitals, as defined in Article 28 of the NY Public Health Law, generally must begin...more
On October 16, the New York Department of Financial Services (DFS) issued a circular letter addressing cybersecurity risks related to the increasing use of artificial intelligence (AI) in relation to insurers, insurance...more
What is a Management Body? Under both DORA and NIS2, a management body can be a body with managerial and/or supervisory functions. The powers and structure of management bodies vary within the EU Member State, and managerial...more
The SEC continued its recent onslaught of proposed cybersecurity rules in mid-March with three new proposals covering a litany of entities, including investment advisers, broker-dealers, investment companies, clearing...more
The Federal Trade Commission will have its eye on privacy and data security enforcement in 2023. In August, the agency announced that it is exploring ways to crack down on lax data security practices. In the announcement,...more
On July 29, 2022, the New York Department of Financial Services (NYDFS) published the pre-proposed second amendment to its Cybersecurity Regulations, 23 NYCRR 500 (Part 500), that if adopted, would likely require numerous...more
The current COVID-19 pandemic has forced many businesses online in order to survive. In many cases, businesses had no plans to be online. Others were forced to move online more quickly than planned. In order to assist these...more
• On May 23, 2019, the Securities and Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations (OCIE) issued a Risk Alert describing its observations in past examinations of weaknesses and best practices...more
On May 23, 2019, the United States Securities and Exchange Commission (“SEC”)’s Office of Compliance Inspections and Examinations (“OCIE”) issued a Risk Alert entitled “Safeguarding Customer Records and Information in Network...more
This client alert will briefly outline key upcoming deadlines under the New York State Department of Financial Services (DFS) Cybersecurity Regulation (the “Regulation”). These include annual filing deadlines coming up in...more
On September 4, 2018, the third stage of compliance deadlines under the New York Department of Financial Services’ (DFS) expansive cybersecurity regulation went into effect....more
The New York Department of Financial Services cybersecurity regulation 23 NYCRR 500 (the “Regulation”) came into effect in March 2017 and established four staggered compliance deadlines for its various requirements. By the...more
Is this a Start of Something New for Third-Party Management? The demand for responsible cybersecurity in business is ubiquitous. The need to protect information is not limited to the financial services, insurance and...more
Almost all parties are required to exchange personal data as part of a merger and acquisition transaction. With data breaches on the rise, any buyer in a M&A transaction cannot afford to ignore privacy and data security...more
On September 13, 2016, the New York State Department of Financial Services (DFS) proposed new rules that would require certain “Covered Entities” to establish and implement cybersecurity programs designed to protect nonpublic...more
On November 9, 2015, the New York Department of Financial Services (NYDFS) issued a letter that describes what insurers can expect from the Department’s ongoing assessment of cybersecurity measures. The letter parallels...more