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Financial Services Law Insights and Observations

NYDFS settles with title insurance company for $1 million

Privacy, Cyber Risk & Data Security State Issues Securities NYDFS Auto Insurance Enforcement

Privacy, Cyber Risk & Data Security

On November 27, the NYDFS entered into a consent order with a title insurance company, which required the company to pay $1 million for failing to maintain and implement an effective cybersecurity policy and correct a cybersecurity vulnerability. The vulnerability allowed members of the public to access others’ nonpublic information, including driver’s license numbers, social security numbers, and tax and banking information. The consent order indicates the title insurance company discovered the vulnerability as early as 2018. The title insurance company’s failure to correct these changes violated Section 500.7 of the Cybersecurity Regulation.

In May 2019, a cybersecurity journalist published an article on the existence of a vulnerability in the title insurance company’s application, that led to a public exposure of 885 million documents, some found through search engine results. The journalist noted that “replacing the document ID in the web page URL… allow[ed] access to other non-related sessions without authentication.” Following the cybersecurity journalist’s article, and as required by Section 500.17(a) of the Cybersecurity Regulation, the title insurance company notified NYDFS of its vulnerability, at which point NYDFS investigated further. The title insurance company has been ordered to pay the penalty no later than ten days after the effective date.