We
previously reported on the New York Department of Financial
Services' proposed cybersecurity regulations. During the public
comment period, the DFS received over 150 comments. In response,
the DFS announced on December 28, 2016, that it had
revised the proposed regulations and delayed their effective date
two months. On February 16, 2017, the DFS confirmed the final regulations will take
effect March 1, 2017, with required compliance 180 days thereafter
(August 28, 2017). These regulations apply not only to property
casualty insurers licensed in New York, but also to many of their
commercial policyholders and insured vendors subject to DFS
regulatory authority.
During the comment period, many small and medium-sized companies
were particularly active in expressing their objection to the
"one size fits all" approach of the original proposed
regulations. DFS attempted to address these concerns in the revised
regulations by making an organization's design for
