NYDFS Publishes Official Amendments to Its Cybersecurity Regulation

11 November 2022
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Highlights of what we learned from the revisions:
  • NYDFS took the time to ingest comments and clarify interpretations, so the next round of comments is very important.
  • The Revised Proposal softens the definition of Class A companies.
  • The Revised Proposal softens the prescriptive requirements around key controls, bringing back some of the risk-based elements of the existing Part 500.
  • NYDFS understands that the implementation periods for some technical elements were too aggressive and has softened those requirements.