Blank, Bonaccorsi ()
The New York State Department of Financial Services (DFS) received numerous comments on its proposed Cybersecurity Requirements for Financial Services Companies (Initial Regulations) and, on Dec. 28, 2016, issued updates to the Initial Regulations (Amended Regulations).1 The Amended Regulations resolve certain issues, but key questions remain. This article explains why the changes in the Amended Regulations are important to “Covered Entities,” and identifies important questions that still need to be resolved.
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