Laboratories of Invention: NYDFS Reaches Out to Regulate Consumer Credit Reporting Agencies

F. Paul Greene, partner and chair of the Privacy and Data Security practice group, provides the background and insights on recent amendments to Article 23 of the New York Codes, Rules and Regulations (NYCRR), issued by the New York State Department of Financial Services, and specifically the impact on consumer credit reporting agencies and the increasing complexity of cybersecurity regulation in the US generally.

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