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This update provides an overview of the legal and regulatory considerations surrounding the use of artificial intelligence (AI) products and New York law in insurance products; with a particular focus on underwriting,...more
On May 1, 2025, additional cybersecurity requirements introduced by the Second Amendment to the New York Department of Financial Services (NYDFS) Cybersecurity Regulation (23 NYCRR Part 500) (the “Second Amendment”) took...more
After years of regulatory uncertainty, the Trump administration has signaled a new approach to digital assets, including by establishing a working group focused on digital assets and nominating crypto-friendly chairs to the...more
On May 1, 2025, additional enhanced cybersecurity controls required by the Second Amendment to the New York Department of Financial Services (NYDFS) Cybersecurity Regulation (23 NYCRR Part 500) (the “Second Amendment”) take...more
As part of a multiyear rollout, the New York Department of Financial Services (NYDFS) has established May 1, 2025, and November 1, 2025, as effective dates for certain amendments to its cybersecurity regulations. These...more
Our Privacy, Cyber & Data Strategy Team highlights the increasingly specific cybersecurity controls identified by regulators, explains why these enhanced cybersecurity controls have become the focus of regulators, and shares...more
In November 2023, New York State's Department of Financial Services (NYDFS) amended its cybersecurity regulation, Part 500. This legal alert provides an update for Covered Entities and Class A Businesses on the current NYDFS...more
Digital Asset Companies Announce New Partnerships, Acquisitions, Products - A recent press release announced that Ripple, a U.S. fintech and digital asset infrastructure provider, has agreed to acquire Hidden Road, a prime...more
On March 20, the New York Department of Financial Services (NYDFS) entered into a consent order with a money transmitter, joining a group of state financial regulators acting through a multi-state task force coordinated by...more
On April 3, 2025, the New York State Department of Financial Services (“DFS”) issued reminders about upcoming implementation and reporting deadlines related to its cybersecurity regulations. Upcoming deadlines require...more
In November 2023, the New York Department of Financial Services (NYDFS) issued its second amendment to its "Cybersecurity Requirements for Financial Services Companies (the Cybersecurity Regulation or Part 500). This was the...more
Businesses that are subject to the NYDFS Cybersecurity Regulations have four weeks left to submit their annual notices of compliance or acknowledge their noncompliance. When the regulations were amended in 2023, several of...more
Welcome to the “Data Privacy and Cybersecurity” chapter of our annual report, Consumer Financial Services: 2024 Year in Review. Consumer financial services regulators are taking a keen interest in artificial intelligence...more
As we previously reported, in 2023 the New York State Department of Financial Services (NYDFS) amended its cybersecurity regulation, 23 NYCRR 500 (or Part 500). As of November 1, 2024, Class A Companies and Covered Entities...more
Financial firms doing business in New York should be mindful of a recent e-blast sent by the state’s financial regulator concerning cybersecurity requirements that become effective in less than two months. The New York...more
On February 27, NYDFS reminded covered entities subject to the Cybersecurity Regulation to submit their annual compliance notifications for the 2024 calendar year. Covered entities must submit the compliance filing by April...more
On February 14, the Governor of New York signed into law SB 804 (the “Act”), which amends the general business law concerning when and how notifications for data breaches are provided to the New York Department of Financial...more
On December 24, New York Gov. Kathy Hochul (D) signed into law an amendment to section 899-aa of the N.Y. General Business Law, also known as The Shield Act, modifying the law’s data breach notification requirements....more
On January 23, 2025, PayPal settled an enforcement action brought by the New York State Department of Financial Services (NY DFS) for failing to comply with cybersecurity regulations required for financial services businesses...more
Stablecoins, which are digital assets pegged to fiat currency or other assets, play a crucial role in crypto markets, offering price stability and facilitating transactions. Despite their growing significance, there is no...more
On January 23, 2025 the New York Department of Financial Services (NYDFS) announced proposed regulations to curb overdraft fees and insufficient funds fees charged by banks in New York. The proposed rules aim to protect...more
What Happened? On December 21, 2024, New York Governor Kathy Hochul, signed into law, S7532, which repealed the existing section of the Banking Law addressing the removal of officers, directors, and trustees of banking...more
On October 16, 2024, the New York State Department of Financial Services (the "DFS"), under its Cybersecurity Regulation—23 NYCRR Part 500—issued a memorandum providing guidance on the risks posed by artificial intelligence...more
On November 1, 2024, the next phase of several significant amendments to the New York Department of Financial Services’ (NYDFS) cybersecurity regulation take effect. These specific amendments, enacted in 2023, impact the...more
On October 16, 2024, the New York State Department of Financial Services (DFS) issued an industry letter providing guidance on how DFS-regulated entities (covered entities) should be evaluating and responding to artificial...more