Today, on May 1, 2025, additional enhanced cybersecurity controls required by the Second Amendment to the New York Department of Financial Services (NYDFS) Cybersecurity Regulation (23 NYCRR Part 500) (the “Second Amendment”) take effect. Although the Second Amendment was originally adopted in November of 2023, NYDFS established a multi-year rollout of the Second Amendment’s requirements, […]
NYDFS
New York Amends Data Breach Notification Law with Immediate Implications
In late December 2024, the New York Governor signed two bills (S2659B and S2376B) amending the state’s data breach notification law (N.Y. Gen. Bus. Law § 899-aa), to expand the definition of reportable personal information and impose new covered entity reporting obligations in the event of a data breach. Effective immediately, companies will have 30 […]
NYDFS Issues Guidance on Artificial Intelligence-related Cybersecurity Risks
On October 16, 2024, the New York Department of Financial Services (“NYDFS”) issued an industry letter covering Cybersecurity Risks Arising from Artificial Intelligence and Strategies to Combat Related Risks (the “Industry Letter”). The Industry Letter contains guidance for entities regulated by NYDFS (“Covered Entities”) in assessing and responding to cybersecurity risks related to the use […]
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 […]