On December 28th, 2016, the New York State Department of Financial Services (DFS or the Department) published a revised version of its proposed regulation governing cybersecurity requirements for all entities required to operate in New York under a license, registration, or similar authorization issued by the Department (the Revised Proposal). Its provisions are scheduled to take effect on March 1, 2017, with phased-in implementation dates. DFS received over 150 comments in response to its originally proposed cybersecurity regulation (the Original Proposal), which led to the issuance of the Revised Proposal. Many of the comments addressed the perceived rigidity and excessively prescriptive requirements of the Proposal’s core provisions. Although the Revised Proposal included some significant revisions addressing those comments, a number of open questions remain. The publication of the Revised Proposal triggers a new opportunity for public comment, which continues until January 27th, 2017. The final version of the regulation could have a significant impact on entities nationwide, as the DFS language has the potential to become a template used throughout the country.

To learn more about this, please see the GT Alert “NYS Department of Financial Services Releases Revised Proposed Addressing Cybersecurity Requirements for Financial Institutions.”

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Photo of Harold N. Iselin Harold N. Iselin

Harold N. Iselin is the Managing Shareholder of the firm’s Albany office and Co-Chairs the firm’s Government Law and Policy Practice. He focuses his practice on governmental affairs, health care, and insurance matters, representing diverse clients before the New York State executive branch…

Harold N. Iselin is the Managing Shareholder of the firm’s Albany office and Co-Chairs the firm’s Government Law and Policy Practice. He focuses his practice on governmental affairs, health care, and insurance matters, representing diverse clients before the New York State executive branch and state legislature. Additionally, he has represented numerous clients in managed care and insurance transactions, often involving complex regulatory issues.

According to Chambers USA 2019 Guide, sources describe Harold as “phenomenal, extremely knowledgeable and pragmatic.” He was described by sources in the 2018 Guide as “the best healthcare regulatory lawyer going, period,” and being “superbly connected with government agencies.”

Prior to joining the firm, Harold was a trial attorney in the U.S. Department of Justice, following which he became Assistant Counsel to the Governor of New York with responsibility for transportation, education, veteran’s affairs and freedom of information matters.

Photo of Joshua L. Oppenheimer Joshua L. Oppenheimer

Joshua L. Oppenheimer focuses his practice on New York State governmental affairs and issues relating to governmental ethics, lobbying laws and campaign finance. He represents clients before the New York State legislative and executive branches, focusing on legislation and regulation involving health, environmental…

Joshua L. Oppenheimer focuses his practice on New York State governmental affairs and issues relating to governmental ethics, lobbying laws and campaign finance. He represents clients before the New York State legislative and executive branches, focusing on legislation and regulation involving health, environmental, labor, and transportation policy, as well as racing and gaming issues.

Josh also has wide-ranging experience advising clients on compliance with the complex federal, state and local laws that govern political activity, lobbying, and general interactions between government and the private sector. Josh counsels companies, trade associations, nonprofit organizations, political parties, political committees, candidates, and public office holders, on compliance with laws regarding campaign finance, elections, ethics, and lobbying. He works with clients to form and administer political action, candidate, and independent expenditure committees, and has the unique experience of aiding in the creation and ensuring the continued existence of a statewide political party. Josh also regularly works with lobbying firms, public affairs companies, and other advocacy groups to navigate the labyrinth of laws pertaining to contacts with government, public disclosure of lobbying activity, and gifts to public officials. He also assists clients with New York ballot access issues.

Photo of Michael J. Murphy Michael J. Murphy

With nearly three decades of experience in life, property, casualty, and workers compensation insurance matters, Michael J. Murphy is a skilled New York insurance legislative and regulatory attorney.

Michael has been involved in many noteworthy insurance matters that have come before the New

With nearly three decades of experience in life, property, casualty, and workers compensation insurance matters, Michael J. Murphy is a skilled New York insurance legislative and regulatory attorney.

Michael has been involved in many noteworthy insurance matters that have come before the New York State Legislature and the New York State Department of Financial Services, including most recently, ride sharing, climate change, and cybersecurity. Michael represents a number of national property casualty and life insurance carriers and, as a result, has strong ties to the major insurance industry trade associations and groups. In addition, Michael has a broad background in New York taxation, environmental and tort matters both before the Legislature and State agencies.

Michael’s practice is a continuation of his experience from serving as the Assistant Counsel to the New York Senate Majority, during which time he focused on insurance, banking, housing, and energy matters, as well as floor counsel. After Michael’s state service, and prior to joining GT, Michael was Assistant Vice President for the American Insurance Association, where he directed their New York government relations program.