On March 1, 2017, new cybersecurity rules went into effect for entities regulated by the New York State Department of Financial Services (DFS). The Cybersecurity Requirements for Financial Services Companies are designed to help protect business and customer information and the IT systems of the entities that DFS regulates. While the Cybersecurity Requirements took effect on March 1, regulated entities have 180 days to comply. The final requirements are available here.

Who Is Regulated? 

The Cybersecurity Requirements apply to companies “operating under or required to operate under a license, registration, charter, certificate, permit, accreditation or similar authorization under the banking law, the insurance law or the financial services law” (“covered entities”). Covered entities include banks, savings and loans, trust companies, check cashers, credit unions, money transmitters, lenders, insurers, holding companies, investment companies, mortgage brokers, originators, and servicers, and certain other regulated types of companies doing business in New York. Smaller covered entities are exempt from certain components of the Cybersecurity Requirements, but they are required to file an exemption form with DFS.
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