DFS Warns About Cyber Non-Compliance, Announces Oct. 19 Webinar

The New York State Department of Financial Services (DFS) has begun contacting insurance agencies and other businesses about their failure to submit the required cybersecurity compliance filings. The emails, which are apparently being sent now, instruct the recipients to make their filings with 15 days.

The department’s Cybersecurity Requirements For Financial Services Companies regulation applies to insurance, banking, and financial services firms licensed or chartered to do business in New York. It provides several requirements for “covered entities” (the regulation’s term for those subject to the requirements.) A limited set of requirements apply to smaller entities, primarily insurance agencies, who don’t exceed certain size parameters (employee count, revenue, gross assets.)

The regulation requires all covered entities to submit compliance filings on the DFS website annually between January 1 and April 15. The filing is either a Certification of Material Compliance (for those entities that were in compliance with all applicable requirements at the end of the prior calendar year) or an Acknowledgement of Non-Compliance for those who were not.

If your agency receives one of the DFS emails this week, their records do not show a compliance filing associated with the agency’s license number. We urge you to complete the filing as soon as possible.

The DFS email states that they will conduct a webinar on Monday, October 19, at 1:00 pm. The webinar will discuss the compliance filing requirements, who must comply with them, and how Covered Entities can submit their compliance filings. Online registration is available.  

Big I New York offers several resources to help members comply with this requirement, including a recording of a webinar conducted last April that demonstrated how to complete the filings. Other resources, including the department’s step-by-step instructions and a checklist of requirements for limited exempt entities, are available on the Filing Instructions page in the Cybersecurity section of this website.

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