On November 1, 2023, the New York Department of Financial Services (“NYDFS”) finalized the amendment to its cybersecurity regulation (the “Amendment”). The Amendment expands cybersecurity requirements across many areas—from governance to incident response to access controls.

The Amendment follows the three published drafts: two proposals published for formal notice and comment in November 2022 and June 2023, and a pre-proposal draft published in July 2022. The final version resembles the June 2023 proposal, but includes a handful of key changes and clarifications. In this Legal Update, we analyze the new requirements introduced in the Amendment.

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