Cybersecurity Law Report | Two Settlements Show NYDFS’ Hidden Power to Use Other States’ Breach Laws

The New York Department of Financial Services (NYDFS) has released a new set of Frequently Asked Questions (FAQs 18–23) under 23 NYCRR Part 500, reinforcing its position that multifactor authentication (MFA) remains a critical component of a covered entity’s cybersecurity program. These FAQs provide highly prescriptive guidance, including clarifications on technical requirements for the “possession” […]

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On October 21, 2025, the New York Department of Financial Services (“NYDFS”) published an Industry Letter (the “Letter”) outlining guidance on managing risks related to third-party service providers (“TPSPs”). NYDFS recognizes that as covered entities become more reliant on TPSPs, managing TPSPs “remains a crucial element of a Covered Entity’s cybersecurity program.” The Letter outlines the actions […]

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On October 21, 2025, the New York Department of Financial Services (“NYDFS”) published an Industry Letter (the “Letter”) outlining guidance on managing risks related to third-party service providers (“TPSPs”). NYDFS recognizes that as covered entities become more reliant on TPSPs, managing TPSPs “remains a crucial element of a Covered Entity’s cybersecurity program.” The Letter outlines […]

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Rhode Island has enacted Senate Bill 603 (SB603), effective July 2, 2025, establishing a comprehensive cybersecurity framework for nonbank financial institutions licensed by the state’s Department of Business Regulation (DBR). Although SB603 is closely modeled after the New York Department of Financial Services’ (NYDFS) Cybersecurity Regulation, 23 NYCRR Part 500 (Part 500), SB603 introduces several […]

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