New York just finished a series of adjustments to its data breach notification requirements. Effective immediately, organizations must notify impacted individuals of a data breach within 30 days of its discovery instead of “in the most expedient time possible and
NYDFS settles with insurance companies over failures in their cybersecurity programs


On November 25, 2024, the New York State Department of Financial Services (“NYDFS”) announced it settled with two large insurance companies over allegations of inadequate data security practices in violation of New York’s cybersecurity regulation (23 NYCRR Part 500) (the…
New York hospitals have new cybersecurity requirements
On October 2, 2024, the New York State Department of Health (DOH) published a new cybersecurity regulation (10 NYCRR 405.46) for all general hospitals licensed pursuant to article 28 of the Public Health Law. Although most of the regulation will…
New York Department of Financial Services addresses cybersecurity risks from artificial intelligence




On October 16, 2024, the New York Department of Financial Services (“NYDFS” or “DFS”) issued guidance raising awareness about combatting cybersecurity risks arising from artificial intelligence (“AI”) used by DFS licensees, such as insurers and virtual currency businesses. Risks revolve…
NYDFS issues significant guidance on insurers using AI or external data


On January 17, 2024 the New York Department of Financial Services (“NYDFS”) published a Proposed Insurance Circular Letter (“Proposed Circular”) regarding the use of artificial intelligence systems (“AIS”) and external consumer data and information sources (“ECDIS”) in insurance underwriting and…
$8 million penalty to NYDFS – and another case of over-retention


2024 was not a happy new year for Genesis Global Trading, Inc. (“GGT”). On January 3, 2024, the New York Department of Financial Services announced a consent order with GGT, where GGT agreed to pay NYDFS $8 million and to…
NYDFS releases major update to Part 500 cybersecurity requirements for financial services companies

On November 1, 2023, the New York Department of Financial Services (“NYDFS”) released the finalized amendments of Part 500 of its cybersecurity regulations. These revisions represent the most significant modifications since the enactment of the rules in March 2017. Noticeably…
NYDFS finalizes cybersecurity rule amendments


On November 1, 2023, the New York Department of Financial Services (NYDFS) finalized the second amendment to its cybersecurity regulations, which are available here. The rules contain the provisions we had described in the original NYDFS proposal a year…

NYDFS proposes significant cybersecurity regulation amendments


On November 9, 2022, the New York Department of Financial Services (NYDFS) officially proposed changes to its cybersecurity regulation and opened a 60-day public comment period. NYDFS had issued a “pre-proposed” version of the changes in July of this year…
NYDFS settles with EyeMed for $4.5 million


On October 18, 2022, the New York Department of Financial Services announced a settlement with EyeMed, a licensed life, accident, and health insurer, with respect to a security incident that occurred in 2020. The settlement claimed that EyeMed had committed…