NYDFS 23 NYCRR 500 Compliance & Cybersecurity Services

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Protect Your Business & Meet Regulatory Obligations
The New York Department of Financial Services (NYDFS) enacted 23 NYCRR Part 500 to ensure that financial services companies implement robust cybersecurity programs. Covered entities must design a program that protects information systems, appoint a chief information security officer (CISO), perform regular penetration tests, maintain an audit trail, conduct risk assessments and manage third-party service providers (Meeting the Third-Party Risk Requirements of 23 NY CRR). Recent amendments expand requirements (e.g., multi‑factor authentication, annual training on emerging threats like AI) and impose strict reporting deadlines, including notifying NYDFS within 72 hours of certain cyber incidents (NYDFS Cybersecurity Regulation (23 NYCRR Part 500)). Non‑compliance may lead to fines starting at $2,500 per day (New York State Cybersecurity Compliance).

NYDFS 23 NYCRR 500 Compliance Checklist

Our team created a concise checklist to guide you through the core obligations. Use this to assess your readiness and identify gaps in your cybersecurity program:

  • Cybersecurity Program (500.02) – Establish and maintain a comprehensive program with policies and procedures tailored to your risk assessment and NIST‑aligned frameworks.
  • CISO Appointment (500.04) – Designate a qualified chief information security officer responsible for overseeing the program, reporting to senior management and the board.
  • Penetration Testing & Vulnerability Assessments (500.05) – Conduct annual penetration tests and bi‑annual vulnerability assessments to identify and remediate weaknesses.
  • Audit Trail (500.06) – Maintain an audit trail to reconstruct financial transactions and detect cyber events. Records must be retained for at least five years.
  • Access Controls & Multi‑Factor Authentication (500.07 & 500.12) – Implement policies to limit user privileges based on need‑to‑know and adopt MFA for remote and privileged access.
  • Application Security (500.08) – Develop and maintain secure software development practices, including code reviews and testing.
  • Risk Assessment (500.09) – Perform annual risk assessments and update them whenever there are material changes, aligning with NIST SP 800 ‑30 (23 NYCRR 500 Risk Assessment, Complete Guide).
  • Third‑Party Risk Management (500.11) – Assess and monitor security practices of vendors and service providers; require contractual safeguards and periodic evaluation.
  • Training & Monitoring (500.14 & 500.06) – Provide continuous cybersecurity training to all personnel (including AI‑threat awareness) and implement controls to monitor user activity.
  • Encryption & Data Protection (500.15) – Encrypt non‑public information in transit and at rest, or implement compensating controls.
  • Incident Response & Business Continuity (500.16 & 500.02) – Develop written incident response and business continuity plans to ensure prompt response and recovery.
  • Notifications & Certification (500.17) – Notify NYDFS of certain cybersecurity events within 72 hours and submit annual compliance certification; file 24‑hour reports for extortion payments when required.
  • Exemptions – Determine whether limited or partial exemptions apply based on company size, employees, or risk (e.g., small businesses).

Cybersecurity & IT Services for Regulated Clients

We specialize in helping financial institutions, insurance companies and other regulated entities achieve and maintain NYDFS 23 NYCRR 500 compliance. Our services include:

  • Compliance Gap Assessment: Review existing policies, procedures and technical controls against NYDFS requirements and provide a prioritized remediation roadmap.
  • CISO Advisory & Virtual CISO Services: Provide experienced cybersecurity leadership to design and manage your program, deliver board‑level reporting and ensure regulatory alignment.
  • Penetration Testing & Vulnerability Management: Perform regular penetration tests, vulnerability scans and code reviews; deliver actionable remediation guidance.
  • Risk Assessment & Third‑Party Management: Conduct risk assessments using NIST‑aligned methodologies; evaluate and monitor vendor security; draft third‑party security clauses.
  • Security Awareness & Training: Develop tailored training programs that address emerging threats (phishing, AI‑generated attacks) and meet NYDFS training mandates.
  • Incident Response & BCDR Planning: Develop and test incident response and business continuity plans, ensuring readiness to meet 72‑hour notification requirements.
  • Audit & Compliance Automation: Implement tools to maintain audit trails, log management, and continuous compliance monitoring.

Why Choose Us?

  • Industry Expertise: Our team has decades of experience serving financial services and regulated organizations.
  • Customized Solutions: We tailor our services to match your business size, risk profile and budget.
  • End‑to‑End Support: From initial gap analysis to continuous monitoring, we provide comprehensive support.
  • Secure & Compliant Practices: We align with NYDFS regulations and industry standards like NIST and ISO 27001.

Ready to Secure Your Business?

Don’t wait until the next compliance deadline. Let our experts help you build a resilient cybersecurity program that meets NYDFS requirements.

Call to Action:

  • Schedule a free compliance consultation with our team to assess your readiness and discuss tailored solutions.
  • Download the NYDFS 23 NYCRR 500 checklist to start your journey toward compliance.

Disclaimer: This page provides general information and is not legal advice. Consult your legal counsel for advice specific to your organization.

Do You Need to Comply? Quick Assessment

  • Are you licensed or registered by the New York Department of Financial Services (NYDFS) or operate as a banking, insurance, or financial services entity in New York?
  • Do you handle or maintain non‑public personal information (NPI) of New York residents, such as customer financial data or personal identifying information?
  • Does your organization provide services like lending, mortgage servicing, money transmission, virtual currency business, or insurance underwriting in New York?
  • Are you a third‑party service provider to an NYDFS‑regulated entity, with access to sensitive information or critical systems?

If you answered yes to any of these questions, your organization is likely subject to 23 NYCRR 500 and should implement a compliant cybersecurity program. Our team can help you assess your obligations and build a roadmap to compliance.