Nearly 70 Percent of Financial Services Institutions Need to Increase Compliance Efforts for NYS DFS Cybersecurity Regulation

CHICAGO (June 8, 2017) – A poll conducted by Baker Tilly Virchow Krause, LLP (Baker Tilly) indicates nearly 70 percent of financial services institutions will need to significantly increase their efforts to meet Sept. 1, 2018 compliance deadlines for the finalized New York Department of Financial Services (NYS DFS) cybersecurity regulation.

“Section 500.14(a) Training and Monitoring, is going to be one of the most difficult provisions to implement,” Christopher Tait, MBA, CISA, CFSA, CCSK, HITRUST CCSFP, principal with Baker Tilly’s financial services risk practice, said. “The wording of this section is loosely defined, so it becomes the duty of the institution to determine what constitutes due care inside their organization and to verify adequate monitoring is in place.”

“Another section that will be difficult to implement is Section 500.15 Encryption of Non-public Information,” Russ Sommers, CPA, CISA, senior manager with Baker Tilly’s financial services risk practice, said. “This is going to rely heavily on data classification and the organizations’ ability to map the flow of data in and out of their network, which is simple, but not easy.”

Baker Tilly recently held an educational webinar, “The finalized NYS DFS cybersecurity regulations: The 18 month transition,” to assist financial services organizations in understanding the NYS DFS cybersecurity regulation, explicitly discussing the provisions going into effect Sept. 1, 2018 and what financial organizations should be doing to prepare for implementation.

The webinar presenters discussed:

  • An overview of the NYS DFS cybersecurity regulation
  • Provisions in effect now
  • Regulations with a Sept. 1, 2018 transition date
  • The 24 month transition period

Presentation slides and a recording of the webinar are available at

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Baker Tilly Virchow Krause, LLP (Baker Tilly) is a nationally recognized, full-service accounting and advisory firm whose specialized professionals connect with clients and their businesses through refreshing candor and clear industry insight. With approximately 2,800 employees across the United States, Baker Tilly is ranked as one of the 15 largest accounting and advisory firms in the country. Headquartered in Chicago, Baker Tilly is an independent member of Baker Tilly International, a worldwide network of independent accounting and business advisory firms in 147 territories, with 33,600 professionals. The combined worldwide revenue of independent member firms is $3.4 billion.