The beginning of March, and a spell of unseasonably warm
weather, graced the Northeast this week. So too did New
York's first-in-the-nation cybersecurity regulations. As
we reported
here in January, the initial launch of regulations was scuttled
in response to industry concerns about scope and the inability to
modify internal security measures by the established
deadlines. This resistance led New York's Department of
Financial Services ("DFS") to slightly modify the
regulations and delay implementation by one month. The
regulations became effective on March 1, upon publication in the NY
State Register.
On February 16, 2017 Governor Cuomo trumpeted the impending
implementation of the regulations and explained that the
protections will help ensure that the financial services industry
has the necessary safeguards in place to protect both companies and
consumers from serious economic harm caused by cyber-crimes.
Indeed, the final regulations encourage firms to
