Date: November 14, 2016

Issue: Cybersecurity

To: New York State Department of Financial Services

Filing Type: Comment Letter

Description: The undersigned organizations are concerned that the New York State Department of Financial Services’ proposed Cybersecurity Requirements for Financial Services Companies would establish yet another cybersecurity regime in a long line of prescriptive policies impacting industry, not only domestically but internationally.4 It would impose new requirements on companies within an environment of preexisting and overlapping federal and state cyber- and data-security rules. 

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