Skip to main content
Menu Icon Menu Icon

InfoBytes Blog

Financial Services Law Insights and Observations

NYDFS to Revise Proposed Cybersecurity Regulation Following Public Hearing Before State Lawmakers

Banking State Issues NYDFS Privacy/Cyber Risk & Data Security 23 NYCRR Part 500

Consumer Finance

On December 19, the New York Assembly Standing Committee on Banks held a public hearing, receiving testimony about a recently proposed regulation intended to address cybersecurity risks to entities regulated by the New York Department of Financial Services (NYDFS). Previously covered by InfoBytes upon its initial release in September 2016, the proposed regulation has since been subject to a public comment period before final issuance.

The hearing before the NY State Assembly provided an opportunity for representatives from a variety of NYDFS-regulated entities to offer testimony and/or raise objections. Many of the witnesses cited the proposal’s “one-size-fits-all” approach as a source of concern, noting that the proposed regulation currently does not account for variations in the business models, IT system structures, or risk profiles of the institutions they affect. Other concerns raised by the witnesses included onerous reporting requirements, a lack of harmony between the proposal and federal regulations and guidance, high costs of compliance, and even reputational risk arising out of exposure through FOIA Laws. An archived video of the hearing can be accessed here.

Two days after the hearing in Albany, NYDFS indicated that it is now planning to release an updated version of the regulation on December 28—thereby pushing the effective date to March 1, 2017.  InfoBytes will continue to monitor the status of the proposed regulation and will issue an update once NYDFS publishes its revised regulation.

Share page with AddThis