Tag archives: NYDFS

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 pricing. This Proposed Circular does not create or change any legislation, but once finalized, will … Continue reading

$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 surrender its BitLicense (for cryptocurrency trading), due to alleged violations of NYDFS’ cybersecurity and its … Continue reading

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, covered entities are now subject to new requirements imposing heightened responsibilities on Chief Information Security … Continue reading

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 ago (see our blog post here), but include some changes.  NYDFS included comments on the proposed … Continue reading

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, which we had summarized here.  NYDFS retained many of those earlier proposed changes, and made … Continue reading

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 seven violations of the NYDFS Cybersecurity Regulation, including failure to have an appropriate annual risk … Continue reading

NYDFS proposes significant cybersecurity regulation amendments

On July 29, 2022, the New York Department of Financial Services (NYDFS) announced a “pre-proposed outreach” of material proposed changes to almost every section of its cybersecurity regulations, and would affect each entity covered by the current regulations of 23 NYCRR Part 500.  Because this version is the “preposed” copy of the changes, there is … Continue reading

New York State imposes a US$1.5 million penalty in cybersecurity breach case

Norton Rose Fulbright - Data Protection Report blogOn March 3, 2021, the New York Department of Financial Services (NYDFS) announced a Consent Order with a NYDFS-licensed Maine-based mortgage banker and loan servicer settling alleged violations of the NYDFS cybersecurity regulations. (In the matter of Residential Mortgage Services, Inc., March 3, 2021). The Consent Order required RMS to pay $1.5 million, and within … Continue reading
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