In its July 2018 report on “A Financial System that Creates Economic Opportunities,” the U.S. Treasury Department outlined its proposals to identify improvements to the regulatory landscape to “better support nonbank financial institutions, embrace financial technology, and foster innovation.”

The Treasury Report contains over 80 specific recommendations for “Embracing Digitization, Data and Technology,”

On September 4, 2018, the third stage of compliance deadlines under the New York Department of Financial Services’ (DFS) expansive cybersecurity regulation went into effect. This deadline, scheduled for implementation 18 months after the regulation (23 NYCRR 500) initially went into effect in March 2017 triggers Covered Entities’ obligations under the regulation to:

  1. Maintain systems

The New York Department of Financial Services (DFS) issued new regulations requiring every consumer credit reporting agency that “assembles, evaluates, or maintains a consumer credit report on any consumers located in New York State register with the Superintendent of the Department of Financial Services.”

As a result of credit reporting agencies’ new status of having