This alert examines the recent New York State Department of Financial Services (DFS) proposed regulation, “Cybersecurity Requirements for Financial Services Companies” scheduled to take effect on January 1, 2017. If adopted, the proposed cybersecurity regulation would require state-chartered banks, insurance companies and other financial services companies regulated by DFS to implement a variety of cybersecurity protocols, including the creation of a third-party information security policy, prompt notification to the Superintendent of Financial Services on the occurrence of “cybersecurity events,” and the completion of annual cybersecurity risk assessments.

New York State Department of Financial Services Proposes Cybersecurity Regulations for Financial Services Companies