F Paul Greene

March 28, 2018 | New York Law Journal

These new FAQs, and the FAQs issued previously, help clarify areas of uncertainty under Part 500. The problem with the FAQs, however, is that they are non-binding and can be changed at will, however unlikely an abrupt or material change from DFS may be.

By F. Paul Greene

7 minute read

September 13, 2017 | New York Law Journal

F. Paul Greene

By F. Paul Greene discusses the recent Equifax breach, including topics such as what is a breached organization's duty to notify its customers, and the role of risk assessment. He further explores what comes next.

16 minute read

August 25, 2017 | New York Law Journal

F. Paul Greene writes: The day has finally arrived for the financial services industry in New York. The new cybersecurity regulations issued by the New York State Department of Financial Services are officially in force, and for the first time, a single state is regulating cybersecurity on a potentially global scale, and it has done so via the regulatory process, not legislative action.

By F. Paul Greene

16 minute read

February 28, 2017 | New York Law Journal

F. Paul Greene of Harter Secrest & Emery writes: It has been a wild ride for the banking, insurance, and financial services industries in New York over the past five months. But now the New York State Department of Financial Services has released the final version of its cybersecurity regulations, maintaining its new risk-adjusted approach. Important questions concerning the scope and effect of the regulations remain, however.

By F. Paul Greene

16 minute read

October 21, 2016 | New York Law Journal

F. Paul Greene, of Harter Secrest & Emery, explains the draft regulations published by the New York State Department of Financial Services addressing cybersecurity in the financial sector. Described as "first in the nation," the draft regulations are sweeping in scope and reach well beyond core financial institutions, such as banks and lenders.

By F. Paul Greene

16 minute read

May 05, 2014 | New York Law Journal

F. Paul Greene writes: The concerns arising from a data breach can be many—negative press, huge disruptions, the looming threat of litigation. Added to those is the possibility of FTC scrutiny and action under an authority that, until recently, had never been tested.

By F. Paul Greene

7 minute read