Two months after the New York Department of Financial Services (“NYDFS”) updated its Frequently Asked Questions (“FAQs”), which we wrote about here, NYDFS has released updated FAQs on multifactor authentication (“MFA”) that further clarify 23 NYCRR § 500.12. As we previously reported, the FAQs from December 2025 provided prescriptive guidance, including clarifications on technical requirements […]
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NYDFS Releases New Prescriptive FAQs on MFA
The New York Department of Financial Services (NYDFS) has released a new set of Frequently Asked Questions (FAQs 18–23) under 23 NYCRR Part 500, reinforcing its position that multifactor authentication (MFA) remains a critical component of a covered entity’s cybersecurity program. These FAQs provide highly prescriptive guidance, including clarifications on technical requirements for the “possession” […]
NYDFS Issues Guidance on Managing Risks Related to Third-Party Service Providers
On October 21, 2025, the New York Department of Financial Services (“NYDFS”) published an Industry Letter (the “Letter”) outlining guidance on managing risks related to third-party service providers (“TPSPs”). NYDFS recognizes that as covered entities become more reliant on TPSPs, managing TPSPs “remains a crucial element of a Covered Entity’s cybersecurity program.” The Letter outlines […]
NYDFS Issues Guidance on Heightened Cybersecurity and Sanctions Risk from Global Conflict
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 […]
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, […]