Transitional Periods (23 NYCRR 500.22), and
Severability (23 NYCRR 500.23).
Enforcement Action
On March 3, 2021, NYDFS entered into a consent order with RMS under the New York Banking Law. The NYDFS enforcement action commenced from a routine examination that started in March 2020, which uncovered the fact that RMS had experienced an email compromise in March 2019 where an RMS employee with a significant amount of individuals’ personal information stored in their email account was not investigated nor was notification to individuals or regulators provided. Further, NYDFS identified in its examination that RMS did not have a comprehensive Cybersecurity Risk Assessment.
For the settlement of the enforcement action, RMS agreed to pay the penalty of $1.5 million to NYDFS and to commence further improvements to its existing cybersecurity program, including certain cybersecurity controls in compliance with the Cybersecurity Regulation. Of importance, NYDFS observed RMS’s cooperation throughout the examination, which NYDFS noted has appeared to assist RMS in expeditious remediation efforts.