On November 1, 2023, New York Governor Kathy Hochul announced that the New York Department of Financial Services (“NYDFS”) finalized amendments to its Part 500 Cybersecurity Regulations (“Final Amendments”)—the first significant change to the regulations since their inception in March 2017. The Final Amendments generally track previous NYDFS proposed amendments—including the November 9, 2022 proposal that we covered here—with certain important changes.
Continue Reading NYDFS Finalizes Significant Amendments to its Cybersecurity Regulations
On July 22, 2020, New York’s Department of Financial Services (NYDFS) filed its first cybersecurity enforcement action against First American Title Insurance Company (First American), seeking civil monetary penalties for several violations of its cybersecurity regulation, 23 NYCRR §500. Entities subject to New York’s Financial Services Law, such as First American, may be subject to a civil penalty up to $1,000 per violation or up to $5,000 per intentional violation, and according to NYDFS, each instance of unauthorized disclosure of NPI constitutes a separate violation. Therefore, an enforcement action under 23 NYCRR §500 may result in a hefty fine, particularly in the even of a large-scale data breach.