In May 2014, the New York State Department of Financial Services (“the Department”)published a report titled “Report on Cyber Security in the Banking Sector” that described thefindings of its survey of more than 150 banking organizations. The report specificallyhighlighted the industry’s reliance on third-party service providers for critical banking functionsas a continuing challenge. In light of the increasing number and sophistication of cyber attacks,including recent breaches at both banks and insurers, the Department is now considering, amongother regulations, cyber security requirements for financial institutions that would apply to theirrelationships with third-party service providers.
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