On March 1, 2018, the one year transition period within which banks, insurance companies, and other financial services institutions and licensees regulated by the New York Department of Financial Services (“Covered Entities”)  must have implemented a cybersecurity program ends. By March 1, the Covered Entities must be in compliance with the following requirements:

23 NYCRR 500 §§:

  • 04(b): Chief Information Security Officer (“CISO”) – Each Covered Entity must have designated a qualified individual responsible for overseeing and implementing the Covered Entity’s cybersecurity program and enforcing its cybersecurity policy. The CISO of each Covered Entity shall report in writing at least annually to the Covered Entity’s board of directors or equivalent governing body. The CISO shall report on the Covered Entity’s cybersecurity program and material cybersecurity risks.
  • 05:  Penetration Testing and Vulnerability Assessments – The cybersecurity program for each Covered Entity shall include monitoring and testing, developed in accordance with the Covered Entity’s risk assessment. The monitoring and testing shall include continuous monitoring or periodic penetration testing and vulnerability assessment.
  • 09: Risk Assessment – Each Covered Entity shall conduct a periodic risk assessment of the Covered Entity’s information systems sufficient to inform the design of the cybersecurity program as required by this part. The risk assessment shall be carried out in accordance with written policies and procedures and shall be documented.
  • 12: Multi-Factor Authentication –  Based on its risk assessment, each Covered Entity shall use effective controls, which may include multi-factor authentication or risk-based authentication, to protect against unauthorized access. Multi-factor authentication shall be used for any individual accessing the Covered Entity’s internal networks from an external network.
  • 14(b): Training and Mentoring – Each Covered Entity shall provide regular cybersecurity awareness training for all personnel that is updated to reflect risks identified by the Covered Entity in its risk assessment.

A PDF containing detailed descriptions for each requirement is found here.