It has been a wild ride for the banking, insurance, and financial services industries in New York over the past five months. Last September, the New York State Department of Financial Services (DFS) proposed sweeping new cybersecurity regulations for these industries. The proposed regulations were heavily prescriptive, requiring certain specific security controls regardless of circumstance, and drastically altering the regulatory landscape for thousands of companies governed by DFS.
DFS received over 150 separate comments to the proposed regulations, many of which criticized their sweeping scope and prescriptive nature. In response, DFS made significant revisions, publishing a notice of revised rulemaking on Dec. 28, 2016. These revisions marked a shift from a prescriptive approach to a more risk-adjusted approach, which is more in line with the regulatory frameworks that many DFS regulated-entities are already subject to, such as the Gramm-Leach-Bliley Safeguards Rule and HIPAA.
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