In 2010, Congress included a provision in the Consumer Financial Protection Act (CFPA) requiring that the Consumer Financial Protection Bureau (CFPB or Bureau) promulgate rules effectuating what is commonly referred to as “Open Banking.”   Specifically, the rules would require any entity that engages in offering or providing a consumer financial product or service to make

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Sweeping Amendments to NYDFS Cybersecurity Regulation

On November 1, 2023, the New York Department of Financial Services (NYDFS) announced extensive amendments to its cybersecurity requirements for financial institutions issued under 23 NYCRR Part 500.  The amendments are intended to address the evolution in the cybersecurity landscape since the regulation was first enacted in 2017, including

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