New York Department Of Financial Services To Soon Require Extensive Cybersecurity Program

Under proposed regulations by the New York Department of Financial Services ("DFS"), covered entities that are subject to DFS oversight, including banks, insurance companies and other financial institutions, may have approximately 30 days to establish and maintain an extensive cybersecurity program. The proposed regulations, which have yet to be adopted, are scheduled to become effective January 1, 2017, with an additional 180-day transitional period.

With limited exceptions for smaller companies, which may be exempt from certain requirements, covered entities are required to have written policies and procedures designed to ensure the confidentiality, integrity and availability of their information systems.