On June 25, 2018, New York State announced adoption of final Department of Financial Services (DFS) regulations that require consumer credit reporting agencies to register with the DFS. Our blog post on the regulations as proposed last fall can be found here. There were some clarifying changes to the requirements but the basic objectives of registration, reporting, abiding by certain parameters of behavior and complying with the DFS cybersecurity regulations remain the same. The final registration regulations are applicable to every consumer credit reporting agency that within the previous 12 month period has assembled, evaluated or maintained a consumer report on 1,000 or more “New York consumers.” The 1,000 consumer report/12 month threshold is new. The class of New York consumers to whom it is applicable is defined as individuals who are listed as New York residents as reflected in the most recent information in the consumer credit reporting agency’s…
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