Christopher Cwalina is a Partner & Kaylee Cox an
Associate in our
Washington, D.C. office
Last week, the New York State Department of Financial Services
(the Department) issued a set of proposed cybersecurity requirements for
financial institutions. The proposal is a continuation of the
Department's efforts to strengthen cybersecurity practices of
the financial sector. Over the past two years, the Department
conducted surveys of regulated banking organizations regarding
their cybersecurity programs, including
third-party vendor management programs and issued reports with
the survey findings.
The Department identified several concerns resulting from these
reports: (i) companies continue to be challenged by the speed of
changing technologies and the increasingly sophisticated nature of
cyber threats; (ii) third-party vendors pose certain security
risks, given their access to sensitive data; and (iii)
cybersecurity is a "global concern that affects every
