NYDFS Publishes Pre-Proposed Amendment To Cybersecurity Regulations ("Part 500")

On July 29, 2022, the New York State Department of Financial Services (“NYDFS”) published pre-proposal amendments (“Proposed Amendments”)¹ to its cybersecurity regulations (“Part 500”).² While NYDFS will be accepting comments on the Proposed Amendments through its website until Aug. 18, 2022, there will still be a full 60-day notice and comment period before the amendments are final.

Key provisions of NYDFS's Proposed Amendments include: (1) new notification requirements; (2) new obligations for “Class A” companies; (3) new requirements concerning entity governance; (4) modifications to the compliance certification requirement; and (5) clarifications around penalties.

1. Notification Requirements