AFSA’s State Government Affairs team sent a letter to the New York Department of Financial Services (DFS) regarding its recent revised proposed second amendment to the DFS cybersecurity regulations. In the letter, AFSA highlights concerns and suggests clarifications for various sections, including the definition of Chief Information Security Officer (CISO), the use of internal auditors for independent audits, meeting requirements through certification of international cybersecurity standards, clarification on terms like “material inadequacies” and “timely reporting,” and the need for a delayed effective date for compliance due to the significant updates required by the proposed rule amendments.
AFSA also recommended expanding the provision allowing covered entities to meet requirements through the certification of international cybersecurity standards to encompass similar requirements, enhancing flexibility. Additionally, the letter highlighted the burden posed by certain requirements, such as the annual testing of incident response plans with senior officers and executives, advocating for modifications to align the exercise with the roles of those involved to provide unnecessary strain on covered entities, and expressed concerns that the requirement to notify DFS of cybersecurity events at affiliates within 72 hours might be overly broad for multinational corporations.
This letter, along with SGA’s other recent letters, can be found on the direct advocacy section of AFSA’s website.
AFSA Comments on NYDFS Updated Proposed Cybersecurity Amendment
Aug 18, 2023
AFSA’s State Government Affairs team sent a letter to the New York Department of Financial Services (DFS) regarding its recent revised proposed second amendment to the DFS cybersecurity regulations. In the letter, AFSA highlights concerns… Read the rest
Financial Flexibility More Important Than Ever
Aug 17, 2023
We’re still a couple weeks away from Labor Day, but it’s probably not early enough to remind ourselves that consumers are paying more than $700 a month more on average for groceries, gas, and other goods and services than they did two years ago.… Read the rest
News from our Members | PayNearMe on CNBC’s Global Top 200 Fintech List
Aug 15, 2023
PayNearMe has been named one of the World’s Top 200 Fintech Companies by CNBC. The company is included as one of the world’s top 40 digital payments companies. This award recognizes PayNearMe’s cutting-edge payments technology platform,… Read the rest
Joint Trades Comment Letter of FCC Call-Blocking Proposal
Aug 15, 2023
Last week, the American Financial Services Association joined the American Bankers Association, ACA International, Consumer Bankers Association, Credit Union National Association, Mortgage Bankers Association, National Association… Read the rest
News from our Members | Aftermarket Refund Legislation & Risk Mitigation
Aug 07, 2023
Cox Automotive | Aftermarket Refund Legislation & Risk Mitigation
Early auto loan terminations often put extra compliance burdens on lenders: Are you responsible for refunding consumers? How easy is it to follow the rules when they … Read the rest
Joint Trades Comment on FCC TCPA Noticed of Proposed Rulemaking TCPA
Aug 03, 2023
Earlier this week, the American Financial Services Association joined the American Bankers Association, Mortgage Bankers Association, National Association of Federally-Insured Credit Unions, National Council of Higher Education… Read the rest
Elevate in Salt Lake | Laura Udis
Aug 02, 2023
Join Laura Udis, Small Dollar, Marketplace, and Installment Lending Program Manager in the Consumer Financial Protection Bureau’s Research, Markets, and Regulations Division, for a dialogue highlighting some of the CFPB’s recent activity… Read the rest
AFSA Comments on Anti-Consumer Arbitration Provisions
Aug 02, 2023
Last week, the American Financial Services Association, joined by 200 other trade associations, submitted a comment letter to Members of Congress opposing anti-arbitration clauses and provisions that have been recently introduced.… Read the rest
Featured Business Partner | Amsive
Aug 01, 2023
The featured Business Partner for the month of August is Amsive.
Consumers signal individuality in all kinds of ways. Today marketers must listen and act on those signals. At Amsive, we give you the tools to know more and the services to do more.… Read the rest
Become a Business Partner Member today!
Aug 01, 2023
For just the month of August, AFSA is running a promotion you won’t want to miss!
Become a Business Partner by August 31st and receive a complimentary registration to the 2023 AFSA Annual Meeting in Salt Lake City, a $1,550 value!
As an AFSA Business… Read the rest