Lawrence R. Hamilton

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On June 28, 2023, the New York Department of Financial Services (“NYDFS”) published updated proposed amendments to its cybersecurity regulation (the “2023 Proposal”) applicable to “covered entities.”1 Covered entities are any person operating under, or required to operate under, a license, registration, charter, certificate, permit, accreditation or similar authorization under the New York Banking…

On October 22, 2021, the New York Department of Financial Services (“NYDFS”) issued an interpretive letter that provides guidance on how entities regulated by NYDFS (“Covered Entities”) may comply with the NYDFS Cybersecurity Regulation by adopting the cybersecurity program of an affiliate (“Affiliate Program Letter”).1 According to the Affiliate Program Letter, a Covered Entity…

As the decade comes to a close, new technologies are having a major impact on how insurance industry participants conduct their operations – especially how they collect, process, analyze, store and disseminate vast amounts of data – as well as how they interact with those with whom they do business. In recent years, blockchain technology…

By any measure, 2018 was a major year for data privacy regulation. The most significant regulatory development in this area was the European Union’s General Data Privacy Regulation (“GDPR”), which went into effect on May 25, 2018 and establishes what is probably the most rigorous data protection regime currently in existence. As adopted, GDPR includes…

The cybersecurity regulation (“CyberRegs”) adopted by the New York State Department of Financial Services (“NYDFS”) is almost two years old and will be fully in effect by March 2019. The CyberRegs has already had a broad impact on financial institutions that are authorized to engage in business in New York (“Covered Entities”). Furthermore, even for…

The cybersecurity and data privacy landscape continues to change, creating significant new risks for businesses across economic sectors. New types of litigation are emerging, new regulatory regimes are entering into force, and new laws promise yet further compliance challenges in the future. At the same time, a wide range of threat actors are launching more…

On October 24, 2017, the National Association of Insurance Commissioners (NAIC) adopted an Insurance Data Security Model Law. The NAIC Model Law builds on existing data privacy and consumer breach notification requirements by requiring insurance licensees to comply with detailed requirements regarding their information security program and responding to and giving notification of cybersecurity events.…

Cyber threats continue to evolve, and data privacy considerations continue to grow more complex. Whether defending against global ransomware campaigns or adjusting to new legal regimes governing international data transfers, companies of all sizes today face unprecedented cybersecurity and data privacy challenges.

Our practical guide, Staying Ahead of the Curve: Cybersecurity and Data Privacy—Hot Topics…

Bylined article by Financial Services Regulatory & Enforcement partner Jeffrey Taft (Washington DC), Corporate & Securities partner Larry Hamilton (Chicago), Cybersecurity & Data Privacy partner Stephen Lilley (Washington DC) and Financial Services Regulatory & Enforcement associate Matthew Bisanz (Washington DC).

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On February 16, 2017, the New York State Department of Financial Services (“NYDFS”) finalized regulations that mandate cybersecurity standards for all institutions authorized by NYDFS to operate in New York, including many banks, insurance entities and insurance professionals doing business in New York. The final regulations, titled “Cybersecurity Requirements for Financial Services Companies,” implement a

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