On November 1, 2023, the New York Department of Financial Services (NYDFS) published the finalized Second Amendment to its Cybersecurity Regulation (23 NYCRR Part 500), which includes a number of significant and, for many covered entities, onerous changes to its original regulation. The finalized Second Amendment is much like the June 2023 proposed draft (which […]
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FTC Approves New Data Breach Notification Requirement for Non-Banking Financial Institutions
On October 27, 2023, the FTC approved an amendment to the Safeguards Rule (the “Amendment”) requiring that non-banking financial institutions notify the FTC in the event of a defined “Notification Event” where customer information of 500 or more individuals was subject to unauthorized acquisition. The Amendment becomes effective 180 days after publication in the Federal Register. Importantly, […]
NY DFS Releases Revised Proposed Second Amendment of its Cybersecurity Regulation
The New York Department of Financial Services (“NY DFS”) published an updated proposed Second Amendment to its Cybersecurity Regulation (23 NYCRR Part 500) in the New York State Register on June 28, 2023, updating its previous proposed Second Amendment, which was published November 9, 2022. While the language proposed is largely similar to the previous […]
CSBS Releases Cybersecurity Programs to Help Nonbank Financial Services Institutions Improve Cybersecurity Posture
A&B ABstract On August 9, 2022, the Conference of State Bank Supervisors (CSBS) released two cybersecurity tools for nonbank financial services institutions to help them prepare for state cybersecurity examinations and, ultimately, improve cybersecurity maturity and protect financial institution infrastructure. These tools are designed to address key aspects of the Uniform Rating System for Information […]