On January 12, 2024, the New York State Department of Financial Services (“NYDFS”) released a new Industry Letter on the use of self-service password reset (“SSPR”) services, which enable users to reset their own password without the assistance of help desk or IT professionals. The Industry Letter discusses the risks associated with the use of […]
NYDFS Releases Consent Order in First Enforcement Action Brought Under the Cybersecurity Regulations
After a three-year investigation/enforcement action by the New York Department of Financial Services (“NYDFS”), NYDFS entered into a Consent Order with a large title insurer (the “Company”) for its violation of NYDFS’s Cybersecurity Regulation (23 NYCRR Part 500) (the “Regulation”), specifically, its failure to protect non-public information (“NPI”). NYDFS originally brought the enforcement action in […]
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 […]
NYDFS Penalizes bitFlyer $1.2 Million for Violations to Cybersecurity Regulation
On May 1, 2023, bitFlyer USA, Inc. (“bitFlyer”) entered into a Consent Order with the New York Department of Financial Services (“DFS”) for multiple deficiencies in bitFlyer’s cybersecurity program, most notably for failure to conduct periodic risk assessments to sufficiently inform the design of bitFlyer’s cybersecurity program (as required by 23 NYCRR § 500.09(a)). BitFlyer […]
NYDFS Releases Significant Enhancements to its Cybersecurity Regulation in the Proposed Second Amendment
The New York Department of Financial Services (“DFS”) released their proposed second amendment to the Cybersecurity Regulation, 23 NYCRR Part 500 (“Proposed Second Amendment”) on October 9, 2022. DFS issued a minor amendment on April 2, 2020, revising the certification of compliance date (from February to April). The Proposed Second Amendment follows DFS’s “pre-proposed” draft […]