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ARTICLE · 13 AUGUST 2020

NYDFS' First Cybersecurity Enforcement Action - What Happened And Important Lessons For Organizations

Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.
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The New York State Department of Financial Services ("NYDFS") has announced its first enforcement action of NYDFS' Cybersecurity Regulation, Part 500 of Title 23 ...

United StatesTechnology
Cynthia Larose
Cynthia Larose
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The New York State Department of Financial Services ("NYDFS") has announced its first enforcement action of NYDFS' Cybersecurity Regulation, Part 500 of Title 23 ("Cybersecurity Regulation") against First American Title Insurance Company ("First American"), a leading title insurance provider.

NYDFS alleges that First American exposed hundreds of millions of documents containing consumers' sensitive personal information ("Nonpublic Information" or "NPI"). According to the Statement of Charges, from at least October 2014 through May 2019, due to a known vulnerability First American's public-facing website, tens of millions of documents containing consumers' bank account numbers and statements, mortgage and tax, records, Social Security numbers, wire transaction receipts, and drivers' license images were viewable on the open internet for access without any login or authentication requirements.

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