On March 1, 2017, the revised Cybersecurity Requirements for Financial Services Companies adopted by the New York Department of Financial Services (“NY DFS”) became effective. This regulation requires banks, insurance companies, and other financial services institutions to establish and maintain a cybersecurity program and to take other measures to protect against data breaches and cyber attacks. This action by the NY DFS is a significant development in the regulatory landscape for cybersecurity. Even financial institutions not subject to regulation by the NY DFS should be aware that this regulation may be the first in a series of incremental steps by state and federal banking regulators as they continue to consider ways to enhance protection of digital information and management of cyber risks.
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