23 NYCRR 500
NYDFS regulation for financial cybersecurity programs
MAS TRM
Singapore guidelines for technology risk management in financial sector.
Quick Verdict
23 NYCRR 500 mandates prescriptive cybersecurity for NY financial firms with annual certifications and fines, while MAS TRM provides risk-based technology guidelines for Singapore FIs emphasizing governance and resilience. Organizations adopt them for compliance, resilience, and regulatory avoidance.
23 NYCRR 500
23 NYCRR Part 500 Cybersecurity Regulation
Key Features
- Mandates qualified CISO with annual board reporting
- Requires phishing-resistant MFA for high-risk access
- Enforces 72-hour cybersecurity incident notification
- Demands dual CEO/CISO annual compliance certification
- Imposes comprehensive TPSP risk management policy
MAS TRM
MAS Technology Risk Management Guidelines
Key Features
- Board and senior management accountability for oversight
- Proportional controls based on asset criticality
- Third-party risk management beyond outsourcing
- Defence-in-depth cyber resilience requirements
- Annual penetration testing for internet-facing systems
Detailed Analysis
A comprehensive look at the specific requirements, scope, and impact of each standard.
23 NYCRR 500 Details
What It Is
23 NYCRR Part 500 is a mandatory regulation from the New York Department of Financial Services (NYDFS) establishing minimum cybersecurity standards for financial services entities. Its primary purpose is to protect nonpublic information (NPI) and ensure operational integrity through a risk-based cybersecurity program. The approach emphasizes governance accountability, evidence-based compliance, and phased implementation post-2023 amendments.
Key Components
- Core pillars: governance (CISO appointment), risk assessments, technical controls (MFA, encryption, access privileges), TPSP oversight, testing (penetration testing, vulnerability scans), incident response, and annual certification.
- 14 main requirements across sections like 500.2 (Cybersecurity Program) to 500.17 (Notifications).
- Built on risk assessment foundation; Class A companies face enhanced obligations like independent audits.
- Compliance via dual CEO/CISO certification filed April 15, with 5-year record retention.
Why Organizations Use It
Covered entities comply to avoid multimillion-dollar fines (e.g., Robinhood $30M). Benefits include reduced incident risk, stronger vendor contracts, board-level resilience, and alignment with NIST CSF.
Implementation Overview
Phased rollout (up to Nov 2025 for universal MFA); starts with gap analysis, asset inventory, policy updates. Applies to NY-licensed financial firms; no certification but DFS examinations enforce via consent orders.
MAS TRM Details
What It Is
MAS Technology Risk Management (TRM) Guidelines (revised January 2021) are supervisory guidelines issued by the Monetary Authority of Singapore (MAS) for financial institutions (FIs). They provide principles-based guidance on managing technology and cyber risks, emphasizing proportional implementation based on risk profile, complexity, and criticality to ensure confidentiality, integrity, and availability (CIA) of systems and data.
Key Components
- 15 main sections covering governance, risk frameworks, secure development, IT operations, resilience, access controls, cryptography, cyber defense, assessments, and audit.
- Synthesised into 12 core principles like board accountability, asset management, third-party oversight, and defence-in-depth.
- No fixed control count; focuses on outcomes with independent assurance via audit.
Why Organizations Use It
- Meets MAS supervisory expectations to avoid enforcement actions like fines or license issues.
- Enhances cyber resilience, operational stability, and customer trust.
- Supports digital transformation while managing third-party and ecosystem risks.
Implementation Overview
- Risk-based approach: asset inventory, risk assessment, control design, testing.
- Applies to all MAS-supervised FIs (banks, insurers, fintechs) proportionally.
- No formal certification; demonstrated through internal audits, board reporting, and MAS inspections.
Key Differences
| Aspect | 23 NYCRR 500 | MAS TRM |
|---|---|---|
| Scope | Prescriptive cybersecurity for financial entities | Broad technology risk management lifecycle |
| Industry | NY financial services (banks, insurers) | Singapore financial institutions (banks, fintechs) |
| Nature | Mandatory regulation with enforcement | Supervisory guidelines with penalties |
| Testing | Annual pen testing, vulnerability assessments | Annual PT for internet systems, regular VA |
| Penalties | Multi-million dollar consent orders | Fines, license revocation, prohibitions |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about 23 NYCRR 500 and MAS TRM
23 NYCRR 500 FAQ
MAS TRM FAQ
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