New York Department of Financial Services (NYDFS)

Our Global Insurance Industry Year in Review is now in its 10th year. In this report, we discuss developments and trends in insurance industry transactions over the past year, with a particular focus on mergers and acquisitions, corporate finance, insurtech, the insurance-linked securities and convergence markets, as well as tax, regulatory and litigation developments.

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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

On March 5, 2019, the Federal Trade Commission (“FTC”) proposed a number of revisions to its Gramm-Leach-Bliley Act (“GLBA”) regulations, which would (i) change the Safeguards Rule to require financial institutions to implement specific information security controls (in a departure from the FTC’s current non-prescriptive approach to data security), (ii) update its GLBA Privacy Rule

Cybersecurity and data privacy presented some of the most complex legal questions and business risks that multinational companies faced in 2018. Businesses should expect continued growth in cyber and data privacy challenges in 2019.

Cyber attacks became even more sophisticated and severe in 2018, with incidents ranging from exfiltration and extortion schemes, to attacks on

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.

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