Developing Cybersecurity Requirements in Banking (and Other Financial Services) - Ted Augustinos
This article provides a description of some of the critical provisions of the New York Department of Financial Services’ Cybersecurity Requirements for Financial Services Companies and the National Association of Insurance Commissioners’ Model law, and the differences and nuances between them.
The financial services industry has been dealing with requirements for cybersecurity since 1999, but 2017 brought new, significant, and proliferating obligations. The bar for the whole industry was clearly raised by the unilateral action of the New York Department of Financial Services (“DFS”), which adopted a new regulation, Cybersecurity Requirements for Financial Services Companies (“DFS Regulation”).
The DFS Regulation imposes significant new responsibilities on DFS licensees (which includes banks, insurers and producers, mortgage lenders and brokers, and others) over a transition period ending in 2019.
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Ted Augustinos, a member of the steering committee of the Privacy & Cybersecurity Practice Group of Locke Lord and Office Managing Partner of the Firm’s Hartford office, authored an article providing a description of some of the critical provisions of the New York Department of Financial Services’ Cybersecurity Requirements for Financial Services Companies and the National Association of Insurance Commissioners’ Model law, and the differences and nuances between them.