Department of Financial Services
New York Codes Rules & Regulations

NDFS 23 NYCRR Compliance Service

Financial Services Compliance

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If you run a banking, insurance or other financial services organization in New York state, you must comply with the New York Department of Financial Services’ cybersecurity regulations.

The state of New York wants to ensure your bank, financial advisory firm, insurance company or credit union – and their vendors and business partners – follow suitable strong cybersecurity policies in an effort to curb the kind of data breaches that have made headlines in recent years.

Specifically, New York wants your organization to do cybersecurity Risk Assessments and address specific areas related to best cybersecurity practices. There are also several reporting requirements, as well as a requirement to maintain a cybersecurity audit trail.

You also must provide an annual cybersecurity report to the state. If your Risk Assessment finds areas where your organization falls short, you have to describe in that annual report how you plan to remediate those shortfalls.

This extends to companies and firms doing businesses with those banks, insurance companies, credit unions, and wealth management firms. If you are a vendor with access to the data or networks of these entities, your firm also must meet the DFS 23 NYCRR requirements.


Frequently Asked Questions

What does my organization need to address under DFS 23 NYCRR?

You must address issues such as information security, data governance and classification, data asset inventory and device management, access controls and identity management, business continuity and disaster recovery planning, systems operations and availability, network security, network monitoring, physical security and environmental controls, customer data privacy, vendor and third-party Service Providers, Risk Assessment, and Incident Response.

We are a small organization. How are we going to get this done?

If you have fewer than 10 employees and independent contractors, less than $5 million in gross annual revenue in each of the last three fiscal years from the New York business operations of a Covered Entity, and less than $10 million in year-end total assets, you are exempt from some – but not all – of this law’s cybersecurity requirements. If you need help, we recommend you turn to an experienced IT Compliance and cybersecurity vendor.

What happens if we don’t meet these requirements?

If you wish to continue doing business in New York but you are cited with violations of this regulation, you may face thousands of dollars in fines, publicity that your company violates state law, and a continuing requirement to correct your violations. In some cases the department will require you to hire a third party who can resolve your deficiencies to the department’s satisfaction.


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