Randall J. Collins writes:
In my previous post, I reviewed the New York State Department of Financial Services’ (NYDFS) findings and conclusions of survey results of financial institutions and insurers’ programs, costs, and future plans related to cybersecurity.
Anthony J. Albanese – Acting Superintendent of Financial Services – writes in a November 9, 2015 letter to Financial and Banking Information Infrastructure Committee (FBIIC) Members that these conclusions have demonstrated a need for new cybersecurity regulations for financial institutions.
Such “robust regulatory action” would be a coordinated effort between state and federal agencies to create a thorough cybersecurity framework addressing critical concerns as well as covering New York-specific interests.
Potential regulations implemented by the NYDFS would require covered financial entities to meet specific cybersecurity obligations in the following areas:
- Cybersecurity policies and procedures;
- Third-party service provider management;
- Multi-factor authentication (i.e., requiring covered entities to apply such authentication to customer, internal, and privileged access to confidential information as well as any access to internal systems or data from an internal network);
- Chief Information Security Officer (i.e., covered entities will be required to have a CISO responsible for overseeing and implementing a cybersecurity policy, among other duties);
- Application security (i.e., covered entities must have and set forth written policies, procedures, and guidelines to ensure the security of all applications utilized by the entity which need to be updated annually by the CISO);
- Cybersecurity personnel and intelligence (i.e., covered entities will need to hire cybersecurity personnel who can handle certain cyber risks and perform core functions of “identify, protect, detect, respond and recover,” as well as providing mandatory training to such personnel);
- An audit function; and
- Notice of cybersecurity incidents.
Some of these proposed requirements are set forth in more detail below.
Read more on Fox Rothschild Privacy Compliance & Data Security.