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ARTICLE · 18 JULY 2017

New York DFS Updates FAQs To Clarify Applicability Of Cybersecurity Regulation

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With the first compliance deadline now less than two months away, the NYDFS has provided additional clarity concerning its new Cybersecurity Requirements for Financial Services Companies by publishing an update...

United StatesTechnology
Melinda McLellan
Melinda McLellan
Jonathan Forman
Jonathan Forman
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With the first compliance deadline now less than two months away, the New York Department of Financial Services (NYDFS) has provided additional clarity concerning its new Cybersecurity Requirements for Financial Services Companies (the "Cybersecurity Regulation") by publishing an update to previously issued Frequently Asked Questions.

We reported on the forthcoming Cybersecurity Regulation in January and February.

The new FAQs address the applicability of the Cybersecurity Regulation to three different types of entities.1

  • New York Branches of Out-of-State Banks. Pursuant to a 1997 Nationwide Cooperative Agreement among state banking regulators, NYDFS "will defer to the home state supervisor for supervision of New York branches." However, NYDFS "maintains the right to examine branches located in New York" as they still must comply with New York law. Accordingly, NYDFS "strongly encourages all financial institutions, including New York branches of

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