Overview On June 23, 2025, the New York State Department of Financial Services (“NYDFS”) issued an industry letter encouraging all regulated entities to review their cybersecurity and sanctions compliance programs in light of heightened geopolitical tensions. The letter, titled “Impact of Global Conflict on Cybersecurity and Sanctions Risk,” emphasizes the elevated risk environment and reaffirms […]
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Additional Cybersecurity Requirements of NYDFS Part 500 Take Effect Today
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 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 Issues Final Circular Letter Guidance on Use of AI in Insurance Underwriting and Pricing
On July 11, 2024, the New York Department of Financial Services (“NYDFS”) released Insurance Circular Letter No. 7, which establishes guidelines on the use of artificial intelligence systems (“AIS”) and external consumer data and information sources (“ECDIS”) in insurance underwriting and pricing (“Final Circular Letter”). The Final Circular Letter comes in the wake of a […]
NYDFS Releases Circular Letter on Use of AI in Insurance Underwriting and Pricing
On January 17, 2024, the New York State Department of Financial Services (“NYDFS”) issued a proposed circular letter for comment regarding the “Use of Artificial Intelligence Systems and External Consumer Data and Information Sources in Insurance Underwriting and Pricing” (the “Circular Letter”). The Circular Letter details NYDFS’ expectations and guidelines for the use of artificial […]