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An important deadline under the New York State Department of Financial Services’ (DFS) Cybersecurity Regulation is fast approaching. DFS’s Cybersecurity Regulation, contained in 23 NYCRR Part 500, went into effect on March 1, 2017 (the Regulation or Cybersecurity Regulation). The Regulation established cybersecurity requirements for entities licensed by DFS, including banking organizations, insurance companies, and money transmitters.

The first major compliance deadline was Aug. 28, 2017. Entities covered by the Regulation were required, among other things, to: (1) have written cybersecurity policies and procedures approved by the board of directors or a senior officer; (2) appoint a Chief Information Security Officer (CISO); and (3) implement certain controls and plans to protect the safety and soundness of the covered entity’s operations, by that date.

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