Challenges complying with 23 NYCRR 500

New York financial services firms must comply with 23 NYCRR 500, a regulation from the NY Department of Financial Services (NYDFS) that places cybersecurity requirements on all covered NY financial institutions. NYCRR 500 is designed to protect consumers and institutions that do business in New York from increasingly sophisticated cybercriminals anxious to access sensitive customer information.

Cybercriminals are just one of the concerns of NY financial institutions. Another issue is meeting the compliance requirements for NYCRR 500.

Common challenges complying with NYCRR 500 include:

• Lack of an integrated approach. All firms must delegate NYCRR 500 to the Chief Information Security Officer (CISO). The delegation may be a good place to start but fails to encompass the full integrated approach that NYCRR 500 requires. The regulation demands risk assessments, policies, procedures, IT risk, operational risk, third-party risk management, incident response planning and reporting. If your cybersecurity program doesn’t tie to your risk assessments, then your organization is not really following NYCRR 500.
• Producing an audit trail. NYCRR 500 mandates audit trails for all required activities like policies, data forms, assessments and more. Firms that use spreadsheets, word processing software and paper notepads may think they are creating an audit trail, but while such tools may be acceptable for day-to-day office use, they are substandard for audit trails.
• CISO reporting requirement. NYCRR 500 requires the firm’s CISO to annually report to the board on the state of the firm’s cybersecurity program. That involves gathering data, compiling a presentation and then ensuring it contains the most accurate information in terms that board members can understand. It’s critical work that is time-consuming and can be prone to errors when done manually.
• Regulatory reporting time limit. NYCRR 500’s annual statement of certification must be retained for five years. If you struggle to complete an annual certification, imagine going through an audit for a past certification. A breach could lead to an investigation of prior years’ records, schedules and data. Annual compliance is hard enough without the challenge of digging into the last five years to create an auditable report.
• Labor shortage of cybersecurity professionals. NYCRR 500 requires firms to utilize qualified cybersecurity personnel to manage cybersecurity risks and perform core cybersecurity functions. With skilled cybersecurity professionals in high demand, financial firms can struggle to keep them. Departures often mean a loss of continuity in how things are done, underlying the need for strong processes that can withstand personnel changes.

Benefits of using Keylight

The Keylight Platform streamlines process activities and helps cut compliance costs, all while facilitating information technology risk management. Keylight also processes data from vulnerability and configuration scans to provide a holistic risk picture. Users have a single view of all system scans, so severe or critical findings can be addressed first.

With Keylight, you can:

• Embrace integration. The platform’s integrated design provides greater visibility into cybersecurity. From this vantage point, you can see the connections between risk assessments and cybersecurity operations, as well as assess the effectiveness of your internal controls and cybersecurity program. When an incident occurs, Keylight equips you to manage every stage of the incident, from root cause analysis to record-keeping.
• Generate audit trails. Automatically generate audit trails for many NYCRR 500 required activities, including policy management and attestation, procedure management, cyber and third-party risk management and incident response. Every entry and edit in Keylight creates a timestamp record of the change and a version of the document that can be brecalled by date. Day, time, user, change and more are visible and reportable.
• Produce reports and dashboards for management. Keylight’s real-time, configurable reporting engine allows users to quickly create and configure reports and dashboards for higher-ups. In addition, it means reviewers can drill-down to real-time supporting data. It results in informed, timely risk management decisions.
• Respond to inquiries quickly and confidently. Whether it’s a random inquiry about your annual certification or a formal review of an incident from years past, Keylight equips you to answer with confidence and in a timely manner. Keylight offers insights on the IT and business conditions at the time of the inquiry. The platform’s intuitive reporting interface allows users to leverage any version of any document or recreate reports from any point in time.
• Make processes more efficient, less dependent on resources. Keylight brings efficiency and automation to cybersecurity management processes. Having a system and repeatable processes lessen the disruption when cybersecurity professionals leave the organization. Strong processes enable new hires to ramp up faster. You can also easily map to best practice risk management platforms like ISO 27001, NIST 800-53 and NIST CSF. The integration between Keylight and these platforms help simplify meeting NYCRR 500 requirements, saving on compliance costs and freeing up hours for other pressing matters.

The Keylight Difference

The Keylight Platform serves as the core of an effective and integrated cybersecurity program that streamlines compliance with NYCRR 500. It lets users systematize best practices and manage risk processes to make them repeatable, resulting in speed, accuracy and less of a labor-intensive effort. Higher efficiency also comes from the platform’s ability to integrate data from vulnerability and configuration scans. Additionally, Keylight allows you to leverage your existing cybersecurity and risk management frameworks to further simplify NYCRR 500 compliance efforts.

Cybercriminals won’t stop trying to steal your customer information. With Keylight, you can fight back by streamlining compliance with NYCRR 500, as well as managing risk and vulnerabilities, incident response, remediation and more—all within the same platform.