The New York Department of Financial Services (“DFS”) recently issued a revised rules proposal that will add its own cybersecurity requirements to those already in place for banks, insurance companies and other financial services companies. While the proposed rules would only be applicable to financial firms licensed by the New York DFS, they reveal that state regulators are just as concerned about the growing risk of cybersecurity breaches. New York’s proposed rules are the first of their kind in the United States for a state regulator to issue, and may portend a sign of things to come.
Due in part to the nature and volume of the personally identifiable information (PII) they maintain, and partially attributable to the name recognition of some high-profile banks and financial institutions, these firms are increasingly finding themselves at the receiving end of targeted and sophisticated cyber-attacks.
As proposed, 23 NYCRR 500 (“Cybersecurity Requirements for Financial Services Companies”) will require financial institutions under the jurisdiction of the DFS “to establish and maintain a cybersecurity program designed to protect consumers and ensure the safety and soundness of New York State’s financial services industry.”
The Cyber Rules will become effective on March 1, 2017, and covered entities will be required to submit annual certificates of compliance to the DFS beginning February 15, 2018.
Take Action Now to Ensure DFS Compliance
Ascendant creates tailored and risk-based policies and procedures for firms designed to address the DFS Cybersecurity Regulation to include the following areas to the extent applicable to the Company’s operations:
- Information Security
- Data Governance and Classification
- Asset Inventory and Device Management
- Access Controls and Identity Management
- Business Continuity and Disaster Recovery Planning and Resources
- Systems Operations and Availability Concerns
- Systems and Network Security
- Systems and Network Monitoring
- Systems and Application Development and Quality Assurance
- Physical Security and Environmental Controls
- Customer Data Privacy
- Vendor and Third-Party Service Provider Management
- Risk Assessment
- Incident Response
For more information about how we can help you reach compliance with New York’s new DFS Cybersecurity requirements, contact us.