Compliance Briefing — November 1, 2024

Executive briefing: The New York Department of Financial Services (NYDFS) second amendment to 23 NYCRR 500 reaches its last compliance milestone on November 1, 2024. All covered entities must now complete independent cybersecurity audits, deliver annual board reporting, and conduct incident response and business continuity tabletop exercises.

Key compliance checkpoints

Independent audits. Section 500.11 requires annual independent audits of cybersecurity programmes; documentation must evidence scope, findings, and remediation.
Board oversight. Senior governing bodies must receive written updates on programme status, material risks, and remediation progress at least annually.
Testing cadence. Entities must run incident response, business continuity, and disaster recovery exercises that include third parties where relevant.

Control alignment

Risk tiering. Map obligations across Class A companies and smaller entities, ensuring privileged access reviews, asset inventories, and monitoring controls align with Section 500.13.
Evidence management. Centralise audit reports, board minutes, and exercise results in systems that support NYDFS examinations.
Third-party assurance. Refresh vendor risk assessments and contractual clauses to reflect enhanced notification and monitoring requirements.

Enablement moves

Schedule audit committee briefings covering outstanding remediation plans and resource needs.
Update playbooks and runbooks to incorporate ransomware-specific procedures and regulatory reporting contacts.
Benchmark maturity against FFIEC CAT, NIST CSF 2.0, or SOC 2 controls to align board dashboards with familiar frameworks.

Sources

Zeph Tech synchronises NYDFS controls, audit evidence, and board reporting so regulated financial institutions clear the November 2024 enforcement bar.