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NY DFS Issues Sweeping FAQs Affecting Scope of Regulations

  • Written by F. Paul Greene
  • Originally published by New York Law Journal

F. Paul Greene, partner and chair of the Privacy and Data Security practice group, discusses the wide-reaching effects the cybersecurity regulations from the New York State Department of Financial Services (DFS), that went into effect on March 1, 2017, have had in the financial services industry and beyond. Their sweeping scope—applying to any person or entity licensed or otherwise operating under an authorization under the New York Banking, Insurance, or Financial Services Laws—brought thousands of entities into the DFS’ reach, many of which had had only tangential dealings with DFS in the past.

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