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 […]
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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 […]
Ransomware Group, in Midst of Extortion Attempt, Files Regulatory Notice with SEC
Just a month before the Security and Exchange Commission’s (“SEC’s”) Material Cybersecurity Incidents Rule is set to take effect, a ransomware group has apparently taken compliance with reporting requirements into its own hands. On November 15, 2023, the ransomware group known as BlackCat (also known as “AlphV”) posted a notice on its leak site alleging […]
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 […]
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 […]