On October 21, 2025, the New York Department of Financial Services (NYDFS) issued guidance to help licensees comply with its cybersecurity regulation. The non-exclusive checklists may be of interest to companies not licensed by NYDFS and even those not
NYDFS fines licensee $2 million for lack of email retention policy and MFA
On August 14, 2025, the New York Department of Financial Services (“NYDFS”) entered into a consent order with Healthplex, Inc, (“Healthplex”), which is licensed by NYDFS as an independent claims adjuster and as a life and/or accident health insurance agent. …
New York changes data breach law—in December and February
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…