Christopher Cwalina is a Partner for Holland & Knight's Washington, D.C. office.
Kaylee Cox is an Associate for Holland & Knight's Washington, D.C. office.
Previously, we wrote about the forthcoming proposed cybersecurity regulation for financial services companies regulated by the New York Department of Financial Services (NYDFS). The new rules were originally set to take effect on January 1, 2017, but that date has now been extended to permit regulated entities more time to come into compliance with the new requirements. In addition, in response to criticism from regulated entities, the NYDFS will reportedly release a revised version of the regulation on December 28, 2016, followed by another public review and comment period. The new cybersecurity requirements are now scheduled to become effective on March 1, 2017. The rules mark the first of their kind in the cybersecurity space by any U.S. state or federal regulator, though it is likely that other regulators will follow suit, as cybersecurity regulatory oversight continues to increase in the absence of a unified federal standard.
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