NYDFS Issues New Cybersecurity Reporting Guidance

On March 2, 2018, the New York Department of Financial Services (DFS) notified certain Covered Entities, as well as certain of their employees, agents and representatives who are also Covered Entities, of their failure to file a certification of compliance with the DFS's cybersecurity regulations codified at 23 N.Y.C.R.R. Part 500 (Part 500). Shortly thereafter, the DFS issued new guidance regarding the reporting obligations of Covered Entities under Part 500. Banks and other financial services firms and their subsidiaries and affiliates, particularly those that have been notified by the DFS as described above, should review the guidance closely to ensure that applicable Part 500 filing and compliance obligations are being fulfilled in a timely and satisfactory manner.