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Welcome to the Data Privacy and Cybersecurity chapter of our annual report Consumer Financial Services 2023 Year in Review. Looking Ahead to 2024 - Amendments to key rules and regulations will take effect in 2024,...more
New York is the first state to propose cybersecurity requirements for all hospitals operating in the state to address patient safety and other cybersecurity related issues....more
California Court Pauses Enforcement of Most Recent CCPA Regulations until March 2024 - On June 30, 2023, the Superior Court of California, County of Sacramento (California Chamber Of Commerce v. California Privacy...more
On November 9, 2022, New York Department of Financial Services (NYDFS) Superintendent Adrienne Harris announced that the NYDFS formally proposed an updated cybersecurity regulation. Although the updates had previously been...more
The close of 2019 witnessed a significant development in data security law that impacts companies regulated with respect to or engaged in the trading of public securities, as well as those companies that provide services to...more
The New York Department of Financial Services (NYDFS) has issued proposed regulations to implement the legislation enacted in April 2019 that requires servicers of student loans to be licensed, imposes servicing standards,...more
Last week, New York Governor Andrew Cuomo issued a press release directing the New York Department of Financial Services (“NYDFS”) to impose new rules on consumer reporting agencies (“CRAs”). The proposed regulation would...more
Yesterday, New York Governor Andrew M. Cuomo announced that he has directed the Department of Financial Services (DFS) to issue a new regulation requiring “credit reporting agencies to register with” the DFS, as well as...more
Last month, Bond, Schoeneck & King sought an exemption from cybersecurity regulations proposed by the New York State Department of Financial Services (DFS) for colleges, universities and other charitable organizations that...more
On September 13, 2016, the New York State Department of Financial Services (DFS) issued proposed cybersecurity regulations (Proposed Regulations) that would impose significant new obligations on all organizations covered by...more
In early September 2016, the New York Department of Financial Services (“DFS”) proposed a set of data security regulations (the “Proposal”) that would govern financial institutions, banks, and insurance companies subject to...more
The New York Department of Financial Services (NYDFS) recently issued a revised proposed regulation seeking to add its own mandate of cybersecurity requirements to those already in existence for banks, insurance companies and...more
The New York State Department of Financial Services (“DFS”) has released a revised version of its proposed cybersecurity regulations, which set regulatory minimum standards for protecting the customer information and...more
Following a public comment period, the New York State Department of Financial Services (DFS) has published a modified version of new regulations, previously issued on September 13, 2016, aimed at creating higher cybersecurity...more
As we previously reported, in September 2016 the New York Department of Financial Services (the “DFS”) proposed a regulation that would require banks, insurance companies and other financial services institutions regulated by...more
Comments submitted on the proposed regulations criticize the lack of a risk-based approach, overbroad definitions, potential extraterritorial implications, an excessive breach notification threshold and a daunting annual...more
The New York State Assembly Committee on Banks held a public hearing on December 19, 2016, receiving testimony about both the benefits and challenges of a recently proposed regulation to address the growing threat posed by...more
Banks, insurers, and other financial services companies in the Empire State may have to abide by new cybersecurity regulations come January 1, 2017. On September 13, New York Governor Andrew Cuomo and the New York...more
On September 13, 2016, New York Governor Andrew Cuomo announced that the New York Department of Financial Services (the “DFS”) proposed a regulation that would require banks, insurance companies, and other financial services...more
Recently, New York’s Department of Financial Services released its long-awaited proposed cybersecurity regulation, which promises to deliver sweeping protections to consumers and financial institutions alike. The proposed...more
Action item: Banking, insurance, and other financial services companies in New York State must be aware of new comprehensive cybersecurity regulations proposed by the Department of Financial Services that will require covered...more
The New York State Department of Financial Services proposed regulations requiring banks, insurance companies and other NYDFS-regulated institutions to promptly adopt a cybersecurity program and setting forth certain minimum...more
In a presidential election year, Americans are often reminded that “As Ohio goes, so goes the nation.” When it comes to banks, insurers and financial institutions, it may be equally true to say “As goes New York, so goes the...more
New York Governor Andrew M. Cuomo recently announced a proposed regulation to protect New York State from the ever-growing threat of cyber-attacks. The proposed regulation requires banks, insurance companies, and other...more
On September 13, 2016, New York Governor Andrew Cuomo announced a proposal by the New York Department of Financial Services (the DFS) of a rule that establishes cybersecurity requirements for financial services companies...more