Clifford Chance

NYDFS Announces First Enforcement Action Under Cybersecurity Regulation

30 July 2020

On Wednesday, July 22, the New York Department of Financial Services charged First American Title Insurance Company with multiple violations of NYDFS's Cybersecurity Regulation, 23 NYCRR 500.  This is the Department's first enforcement action since the Regulation took effect on March 1, 2017, signalling that the Regulation definitely has teeth and carries the prospect of severe penalties for those who have not yet taken it seriously.  The action thus provides important guidance to NYDFS-supervised entities, particularly given the heightened risk of cybersecurity incidents during the COVID-19 pandemic.

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