By Jennifer Archie, Alan Avery, Serrin Turner, and Pia Naib

Dozens of financial institutions and trade associations have lodged emphatic objections with the New York State Department of Financial Services (NYSDFS) in response to the Department’s September 28, 2016 Notice of Proposed Rulemaking entitled “Cybersecurity Requirements for Financial Services Companies” (the Proposed Rules). As published for comment in the New York State Register, the Proposed Rules would impose expansive new cybersecurity requirements on entities under NYSDFS’ jurisdiction …