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ARTICLE · 29 DECEMBER 2023

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NYDFS Amended Cybersecurity Rules: Overview Of Upcoming Deadlines

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On November 1, 2023, the New York Department of Financial Services (NYDFS) announced the adoption of amendments to its Cybersecurity Regulation 23 NYCRR Part 500...

United StatesTechnology
Natasha Kohne
Natasha Kohne
Michelle Reed
Michelle Reed
Erica E. Holland
Erica E. Holland
Joseph Hold
Joseph Hold
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On November 1, 2023, the New York Department of Financial Services (NYDFS) announced the adoption of amendments to its Cybersecurity Regulation 23 NYCRR Part 500 ("Amended Cybersecurity Rules" or "Amended Rules"). NYDFS adopted changes following formal notice and comment on the proposed amendments released in June 2023 (please find our piece on the proposed amendments here). NYDFS also released an "Assessment of Public Comment" describing why it adopted or rejected certain comments, providing a helpful sight into the Department's approach to the Cybersecurity Regulation.

More Obligations for the Largest Companies

The Amended Rules create a new subcategory for large covered entities called "Class A companies." Class A companies are covered entities with at least $20 million in gross annual revenue from its business operations and its affiliates in New York in each of the last two years, and either: (i) over 2,000 employees, including employees of its affiliates,

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