On November 9, 2015, the New York State Department of Financial Services (“DFS”) sent a letter to a number of state and federal financial regulators signaling that DFS may issue comprehensive cybersecurity regulations for financial institutions subject to DFS’s authority. The stated purpose of the letter was to “spark additional dialogue, collaboration and, ultimately, regulatory convergence among [the various] agencies on new, strong cyber security standards for financial institutions.” Although any cybersecurity regulations issued by DFS would apply only to those financial institutions subject to DFS’s authority, DFS is encouraging state and federal financial regulators to work together to develop a comprehensive cybersecurity framework for all financial institutions “in the weeks and months ahead.”
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