MEMO  
  To: General Agents in New York  
  From: Legal and Regulatory Compliance  
  Re: Cybersecurity Requirements for Financial Services Companies  
  This document is offered for general guidance only, and does not constitute legal advice.  
  Consistent with prior years, we are notifying you of a requirement you need to complete with the New York regulators. Below is the information about this agent requirement.  
  What is it?  
  New York State Department of Financial Services (NYDFS) 23 NYCRR 500 (Cybersecurity Requirements for Financial Services Companies)  
  Link to full regulation: https://www.dfs.ny.gov/docs/legal/regulations/adoptions/dfsrf500txt.pdf
The regulation is “designed to promote the protection of customer information as well as information technology systems of regulated entities.”
 
  When is the deadline for compliance?  
  April 15, 2020 Compliance Certification Filing Deadline  
  Regulated entities and licensed persons must file the Certification of Compliance for calendar year 2019 no later than April 15, 2020.  
  Who has to comply?  
  Each NYDFS licensed individual is a Covered Entity defined by Reg. 500. We have provided a worksheet along with the memo that will help you determine what obligations you have for certifying. By answering the questions in the worksheet, you may find that you qualify for a limited exemption (that you are required to file with the NYDFS), after you file the exemption; you are still required to file certification for the remaining compliance obligation. Since you are a licensed agent in the State of New York, you are required to file with the NYDFS your Certificate of Compliance or file for an exemption prior to April 15, 2020. Some exemptions may apply to an independent contractor if they are covered by the Cybersecurity Program of another covered entity* or if they file for and meet the requirements of an exemption. *NOTE: The Cybersecurity Programs in place at the home office covers home office operations only.  
  Frequently Asked Questions including Exemption guidance: Please refer to the FAQs link for more information: https://www.dfs.ny.gov/industry_guidance/cyber_faqs  
  Filing requirements: All regulated persons and companies that wish to claim an exemption must file a Notice of Exemption with NYDFS stating their current exempt status prior to the certification deadline of April 15, 2020. Previously filed exemptions are set to expire and must be refiled. Any DFS regulated entity or licensed person who filed a Notice of Exemption previously will not need to refile a Notice of Exemption. If there has been changes, you should update your status accordingly  
  What to file if you are licensed by NYDFS but not currently working in that field:  
  500.19(c) applies to any regulated entity or licensed person that does not maintain any Information Systems and does not possess any Nonpublic Information. People who are currently licensed but not actively utilizing such license may fall into this category provided they are not maintaining nonpublic information concerning former or potential consumers or otherwise maintaining information or systems covered by the regulation. This is a partial exemption and still requires that the covered entity or licensed person comply with certain provisions of the Regulation. These include the requirement to conduct a Risk Assessment and submit an annual Certification of Compliance to the Superintendent.  
  If you have questions about this regulation, please email askcompliance@Globe.Life.  
 
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Sent by Aurea on behalf of Globe Life Insurance Company of New York.


 
 
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