Yesterday, it was reported that the New York Department of Financial Services (“NYDFS”) will publish a revised proposal of its proposed cybersecurity regulations. The revised proposal is expected to be published before the New Year.

Please note that a formal comment period will follow any revised proposal. Then, formal publication in the NY State Register is required before the rules can go into effect. Additionally, there likely will be a transition period before the NYDFS will enforce compliance with the rules.

DWT previously described the expected impact of the NYDFS rules although it is not clear the extent to which the anticipated revised rules will be different. We will update you as they are published.