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TCH Responds to NYDFS’s Proposed Cyber Rules

The Clearing House (TCH) responded to proposed cyber regulations (Proposal) issued by the New York Department of Financial Services (NYDFS). The NYDFS’ Proposal seeks to establish generally applicable minimum regulatory standards for NYDFS-regulated financial institutions in the area of cybersecurity. While TCH believes that the Proposal includes many helpful provisions, the comment letter recommends that the Proposal be sufficiently principles-based and adaptable to permit evolution of cybersecurity practices within a risk-management framework. The letter also highlights specific elements of the proposal that should be modified to achieve the proposal’s overall policy objectives in a more effective, secure, and tailored manner consistent with a risk-based approach.