In an early November letter to members of the Financial and Banking Information Infrastructure Committee, the New York Department of Financial Services (DFS) provided a broad framework of cyber security standards that it intends to incorporate in new regulations for financial institutions.

The committee, which is made up of federal and state regulators of financial institutions, including the Federal Reserve Board, the Securities and Exchange Commission, the Federal Deposit Insurance Corp. and the National Association of Insurance Commissioners (NAIC), was established after the Sept. 11, 2001, attacks to improve the reliability and security of the financial sector infrastructure.

While the DFS letter calls for dialogue, collaboration and regulatory convergence on cyber security standards for regulated financial institutions, it also indicates a clear intent on the part of DFS to move forward with regulations in this area with or without cooperation and collaboration from other regulators, including fellow state insurance regulators and the NAIC.

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