Change has been a constant at the New York State Department of Financial Services. Since its first superintendent departed the agency in June 2015, there have been six confirmed and acting superintendents for DFS. With each change in the agency's helm there is an inevitable shift in priorities, including its enforcement emphasis.

In August 2021, Gov. Kathy Hochul appointed Adrienne Harris as DFS Superintendent, shortly after Governor Hochul took office. This article discusses DFS' evident enforcement priorities since the beginning of 2021, and as they have evolved under the new DFS administration, along with what might be expected in the near term.

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Cybersecurity Enforcement: As Promised

DFS officials have repeatedly emphasized that cybersecurity is a central prudential concern. In mid-2021, the agency's top cybersecurity official noted there might be as many as a half-dozen serious cybersecurity investigations underway. See "Cybersecurity Enforcement Activity From NYDFS Fashions Regulatory Expectations," New York Law Journal (June 8, 2021).