The Second Amendment to the New York Department of Financial Services’ (“NYDFS”) Cybersecurity Requirements for Financial Services Companies (the “NYDFS Requirements”) is expected to be published in final form in the next two weeks. The Second Amendment will follow updated proposed amendments to the NYDFS Requirements published on June 28, 2023 (the “2023 Proposal”),1 which were revised after the proposed amendments were first formally published on November 9, 2022.2 The comment period for the 2023 Proposal ended on August 14, 2023.

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