New York DFS Issues New Cybersecurity Guidance
Under New York’s Cybersecurity Regulation, issued in 2017, any entity (a “Covered Entity”) regulated by the New York State Department of Financial Services (DFS) must maintain a risk-based cybersecurity program that protects its information systems and nonpublic data. For years, DFS has allowed Covered Entities to adopt the cybersecurity program of an affiliate. This has…