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ARTICLE · 24 JANUARY 2017

NYDFS: A Lawyer's Responsibility

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Because the final NYDFS regulations will likely largely reflect the current draft of the regulations, companies subject to these regulations should immediately begin to tackle compliance requirements.

United StatesFinance and Banking
Jo-Ellyn Sakowitz Klein
Jo-Ellyn Sakowitz Klein
Natasha Kohne
Natasha Kohne
Michelle Reed
Michelle Reed
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New York Financial Regulator to Enforce First-of-Its-Kind Cybersecurity Regulations in Coming Weeks

On December 28, 2016, the New York Department of Financial Services (NYDFS) issued revised cybersecurity regulations that, as of March 1, 2017, will require Covered Entities—which broadly includes "any Person operating under or required to operate under a license, registration, charter, certificate, permit, accreditation or similar authorization under the Banking Law, the Insurance Law or the Financial Services Law"—to implement a number of data security measures and certify compliance as early as February 15, 2018.  The revised regulations were issued following an initial draft released on September 13, 2016 (Akin Gump blog post here), and a comment period during which more than 150 public comments regarding the initial regulations released on September 13, 2016, were filed.

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