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The European Union’s Digital Operational Resilience Act (DORA) came into effect on January 17, 2025. DORA aims to harmonise rules concerning the provision of information and communication technology (ICT) services to...more
Keypoint: New York’s Division of Financial Services (DFS) now requires Property and Casualty Insurers writing cyber insurance to comply with the Division’s Cyber Insurance Risk Framework to manage their risk. In her...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
Ohio recently followed South Carolina as the second state to adopt cybersecurity legislation modeled after the NAIC’s Insurance Data Security Model Law. The Ohio law, Senate Bill 273, applies to insurers authorized to do...more
March is now here and with it the Cybersecurity Regulation of the New York Department of Financial Services (NYDFS) is now in full force and effect, including requirements relating to Third Party Service Providers (e.g.,...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
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
South Carolina has become the first state to enact a version of the Insurance Data Security Model Law, which was drafted by the National Association of Insurance Commissioners (NAIC) in 2017. Governor Henry McMaster signed...more
The National Association of Insurance Commissioners (NAIC) has approved its draft of the Insurance Data Security Model Law (Model Law) via a meeting of its Executive and Plenary Committees. This important development follows...more
The National Association of Insurance Commissioners (NAIC) Cybersecurity (EX) Working Group (Cybersecurity WG) approved Version 6 (Finalized) of its Insurance Data Security Model Law (Model) on August 7 at the NAIC Summer...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
We have previously reported about the upcoming New York Financial Services Cybersecurity Regulations. On February 16, 2017, Governor Andrew M. Cuomo announced that “the first-in the-nation cybersecurity regulation to protect...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
We previously reported on the New York Department of Financial Services’ proposed cybersecurity regulations. During the public comment period, the DFS received over 150 comments. In response, the DFS announced on December 28,...more
The New York Department of Financial Services (“DFS”) recently issued a revised version of the cybersecurity rules that it first announced in the fall of last year. The rules apply to a wide range of insurance, banking, and...more
As we previously reported, in December 2016 the New York Department of Financial Services (the “DFS”) announced that it was revising its proposed regulation that would require banks, insurance companies and other financial...more
The New York Department of Financial Services (NYDFS) announced today a revised regulation that will require all institutions subject to NYDFS supervision to establish and maintain a cybersecurity program meeting "certain...more
This is the second installment in our interview with Steven Grossman, VP Strategy & Enablement at Bay Dynamics, the cyber risk analytics company. Here, Steven discusses the importance of aligning an institution’s risk...more
Recent data breaches have brought cybersecurity to the attention of insurance companies, and serve as a reminder to third party administrators ("TPAs") that cybersecurity issues are a serious compliance and regulatory...more