NYDFS Snapshot
You're regulated by NY DFS. 23 NYCRR 500 says you need a cybersecurity program. We assess where you stand: applicability, exemptions, gaps, certification readiness.
This is for you if:
- You hold a DFS license (bank, insurance, money transmitter, lender, etc.)
- Your annual certification is coming up and you're not sure you're ready
- You're not sure if you qualify for the small business exemption
- The 2023 amendments expanded requirements and you need to catch up
What you get
Applicability & Exemption Analysis
Clear determination of whether 23 NYCRR 500 applies to you and which exemption tier (if any) you qualify for. Many companies are covered and don't realize it.
Program Gap Assessment
Section-by-section review against all 23 NYCRR 500 requirements. Written policy, risk assessment, access controls, encryption, audit trails—we check everything.
MFA Requirements Review
NYDFS has specific MFA requirements that expanded in 2023. We verify coverage for external access, privileged accounts, and remote network access.
Incident Response Evaluation
Your incident response plan must enable 72-hour notification. We assess your plan, procedures, and whether you can realistically meet the timeline.
Annual Certification Prep
What you need to file your April 15 certification. We identify gaps that would prevent you from certifying compliance in good faith.
Remediation Roadmap
Prioritized list of gaps with specific remediation steps. We tell you what to fix first based on risk, effort, and regulatory priority.
The process
8 steps from intake to complete NYDFS compliance assessment.
Submit intake
Online form
Applicability
DFS coverage
Exemption check
Tier analysis
Class designation
A vs Standard
Section review
All 23 sections
MFA/IR check
Key controls
Gap analysis
Full assessment
Delivery
Full report
Mount WhitneyWhat's included
- Full applicability & exemption analysis
- Section-by-section gap assessment
- MFA requirements verification
- Incident response plan evaluation
- Certification readiness checklist
- Class A designation analysis
- Prioritized remediation roadmap
- 2023 amendment gap review
- 30-day email support
Important
This engagement constitutes a compliance assessment and does not constitute legal advice. Voss Intelligence identifies compliance gaps against 23 NYCRR 500 requirements and prepares documentation supporting certification. The client retains sole responsibility for filing the annual certification and attesting to compliance with applicable regulations.
23 NYCRR 500 Requirements
NYDFS has specific cybersecurity requirements across 23 sections. We assess your compliance with each applicable requirement.
Before vs After
Without assessment
Uncertain about applicability
Unknown exemption status
Gaps discovered at certification
72-hour deadline unrealistic
Filing certification in bad faith
With NYDFS Snapshot
Clear applicability determination
Exemption tier documented
All gaps identified upfront
IR plan ready for 72-hour window
Certify with confidence
Result
Certification-ready by April 15
Common questions
Does NYDFS 23 NYCRR 500 apply to my company?
If you're licensed, registered, or authorized by the NY Department of Financial Services—banks, insurance companies, money transmitters, mortgage brokers, licensed lenders, premium finance agencies, and others—yes, it applies. The regulation covers any entity "operating under" a DFS license. Fintech companies with NY licenses are often surprised to learn they're covered.
What about the small business exemption?
There are three limited exemption tiers. If you have fewer than 20 employees (including affiliates), less than $5M in gross annual revenue for three years, or less than $10M in year-end total assets, you qualify for reduced requirements under Section 500.19. But you're still covered—you just have fewer obligations. The 2023 amendments added a new small business exemption tier. We'll determine exactly which requirements apply to your specific situation.
What is the Class A designation and does it apply to us?
Class A companies face enhanced requirements including independent audits, endpoint detection, and additional board reporting. You're designated Class A if your NY operations generate over $20M in gross annual revenue, you have 2,000+ employees across all affiliates, or you have over $1B in total assets under management from NY operations. Meeting ANY one threshold triggers Class A status.
What are the 2023 amendment changes I should know about?
The November 2023 amendments significantly expanded requirements. Key changes: mandatory endpoint detection and response (EDR), enhanced access privilege management, asset inventory requirements, business continuity planning, independent audits for Class A companies, and expanded CISO reporting to the board. Compliance deadlines are phased through 2025.
What happens if we can't certify by April 15?
You must annually certify compliance by April 15 via the DFS portal. Filing a false certification is a serious violation. If you have known material gaps, you cannot in good faith certify compliance. Options include remediating before the deadline, filing an acknowledgment of noncompliance, or filing with the acknowledgment that material improvements are underway. Penalties can reach $2,500 to $75,000 per day for violations, plus individual liability for officers.
How does the 72-hour notification requirement work?
NYDFS requires notification within 72 hours of determining that a cybersecurity event has occurred that requires notification. That's 72 hours from determination, not from discovery—but you can't unreasonably delay determination. The clock is tighter than most frameworks. You need documented incident response procedures, clear escalation paths, and pre-drafted notification templates to realistically meet this timeline.
Get certification-ready.
We assess your 23 NYCRR 500 compliance, identify gaps, and prepare you for your April 15 certification. 10 days, $2,490, no surprises.
Get Started