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On August 28, 2017, the first transitional period for the NYDFS cybersecurity rule (the “Rule”) ended. Covered entities are now expected to satisfy a number of requirements established by the Rule, including those relating to the implementation of a cybersecurity program and cybersecurity policy, as well as to the designation of a chief information security officer.

New York Cybersecurity Requirements Begin to Go Into Effect

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On August 28, 2017, the first transitional period for the NYDFS cybersecurity rule (the “Rule”) ended. Covered entities are now expected to satisfy a number of requirements established by the Rule, including those relating to the implementation of a cybersecurity program and cybersecurity policy, as well as to the designation of a chief information security officer.The next deadline for the Rule is September 27, 2017. Covered entities that have determined that they qualify for a limited exemption under 23 N.Y.C.R.R. 500.19(a)-(d) are required to file a notice of exemption with NYDFS on or before this date.For more information about the Rule’s requirements and the transitional compliance deadlines, please see our previous <a href="https://media2.mofo.com/v3/assets/blt5775cc69c999c255/bltf00f264649a6c20b/627317ae8e09542a15b7deff/170323-ny-cybersecurity-regulations.pdf">Client Alert</a>. In addition, you can visit the NYDFS <a target="_blank" href="http://www.dfs.ny.gov/about/cybersecurity.htm">webpage</a> for more information about the Rule, including FAQs on the Rule provided by NYDFS.