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Anticipating the first NYDFS cybersecurity enforcement actions

First issued in March 2017, 'Part 500' contained a two-year implementation period and has been fully effective for about nine months.

By Matthew L. Levine | January 10, 2020 at 07:30 AM
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A number of traditional factors that animate decisions about enforcement point to a likelihood in the near term of an enforcement proceeding against one or more regulated entities for a violation of the DFS cybersecurity regulation, known as “Part 500.” A number of traditional factors that animate decisions about enforcement point to a likelihood in the near term of an enforcement proceeding against one or more regulated entities for a violation of the DFS cybersecurity regulation, known as “Part 500.” (Photo: Shutterstock)

The question gets asked quite frequently in regulatory circles: “Will the New York State Department of Financial Services bring an enforcement action under its cybersecurity regulation, and if so, when?”

The probable answers are “yes” and “soon.”

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