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Abstract: 

Financial services companies are facing new and increased risks of cyber-attacks that have the potential to significantly disrupt both the companies and their customers, and potentially to impact the entire U.S. economy. As result, the New York State Department of Financial Services has issued a far-reaching, “first-in-the-nation,” cybersecurity regulation that requires financial services companies regulated in New York to adopt a program and policy to prevent, detect, and respond to cybersecurity threats. This article discusses who is subject to the regulation and the requirements that are imposed, and provides insight on how the regulation is likely to impact the financial services industry as a whole.

Keywords: cybersecurity, Chief Information Security Officer (CISO), monitoring, vulnerability, risk assessment, penetration testing, third-party services provider security

Affiliations:  1: Cullen and Dykman LLP; 2: Cullen and Dykman LLP.