February 15 deadline looms for first DFS Cybersecurity Certification

February 15, 2018, is quickly approaching and any entity subject to New York’s cybersecurity regulation (23 NYCRR Part 500) must file its first annual certification of compliance with the New York State Department of Financial Services (DFS) by that date. New York imposes cybersecurity requirements on all entities (covered entities) subject to the jurisdiction of the DFS, which include not only banks and insurers, but also any persons regulated by the DFS, including the newest DFS licensees, those engaged in virtual currency business activity. Covered entities are required annually to submit a certification to the DFS covering the prior calendar year, certifying that the covered entity is in compliance with the regulation’s requirements. For the first certification due February 15, the certification need only cover a subset of the total items with which a covered entity must comply, including the baseline requirements that the covered entity have a cybersecurity…

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