An important deadline under the New York State Department of Financial Services’ (“DFS”) Cybersecurity Regulation is fast approaching. DFS’ 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 cybersecurity regulation established several transitional periods to allow covered entities time to comply with certain stipulated requirements including deadlines in August 2017, February 2018 and March 2018. The current transitional period, which concludes on Sept. 4, requires covered entities to comply with additional regulatory requirements, including an audit trail, limitations on data retention, encryption of certain nonpublic information, application security and training and monitoring.
