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.