After compliance certifications were to be filed by February 15, 2018, the New York Department of Financial Services (“DFS” or “Department”) answered some questions that had been on the minds of many companies prior to certification. Specifically, the DFS issued four more answers to frequently asked questions about the DFS Cybersecurity Regulation (“Regulation”). These four, of now 30 FAQs, address how the Regulation is to be applied to Exempt Mortgage Servicers, Not-for-Profit Mortgage Brokers, health maintenance organizations (“HMOs”) and continuing care retirement communities (“CCRCs”), and how the Regulation should be considered during the process of mergers and acquisitions.
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