Nathan D. Taylor and Adam J. Fleisher
Banking + Financial Services, Financial Institutions + Financial Services, Financial Services Enforcement, Financial Services Litigation, Financial Services, Privacy + Data Security, and Financial Technology
The closely watched New York State Department of Financial Services cybersecurity standards for covered financial institutions are now final and take effect March 1, 2017 in less than a week. The final rule largely tracks the second proposed rule issued in December 2016. As a result, the final rule is narrower and less prescriptive than the original proposal, but will still present challenges, especially for financial institutions that do not have mature cybersecurity processes and controls in place.
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