What It Is

APRA Prudential Standard CPS 234 (Information Security) is a binding prudential regulation issued by the Australian Prudential Regulation Authority, effective 1 July 2019. It mandates regulated financial entities maintain an information security capability commensurate with threats and vulnerabilities to minimize incidents impacting confidentiality, integrity, or availability (CIA) of information assets, including those managed by third parties. Its risk-based approach emphasizes governance, assurance, and rapid notification.

Key Components

• **Governance pillarsBoard accountability (para 13), defined roles (para 14), policy framework (paras 18-19).
• **Risk managementAsset classification by criticality/sensitivity (para 20), commensurate controls (para 21).
• **AssuranceSystematic testing (paras 27-31), internal audit review (paras 32-34).
• **Incident responseDetection mechanisms, annual plan testing (paras 23-26), 72-hour/10-day APRA notifications (paras 35-36). No fixed control count; focuses on outcomes with third-party extensions.

Why Organizations Use It

Ensures prudential compliance for APRA-regulated entities (ADIs, insurers, super funds), mitigates cyber risks to operations/customers, enables resilience amid outsourcing/cloud reliance. Builds board oversight, reduces incident impact, avoids supervisory penalties.

Implementation Overview

Phased: gap analysis, asset inventory/classification, control/testing programs, third-party assessments. Applies to all sizes of APRA entities/groups; no external certification but internal audit and evidence for supervision. (178 words)

What It Is

23 NYCRR Part 500 is the New York Department of Financial Services (NYDFS) Cybersecurity Regulation, a state-level mandate for financial services entities. Its primary purpose is safeguarding nonpublic information (NPI) and information systems through a risk-based cybersecurity program. It adopts a hybrid approach: prescriptive minimum controls with risk-tailored flexibility.

Key Components

• 14 core requirements including cybersecurity program, CISO governance, MFA, encryption, access privileges, risk assessments, TPSP oversight, penetration testing, incident response.
• Built on risk assessment foundation; annual dual CEO/CISO certification; 72-hour incident notification.
• Compliance via self-attestation; Class A entities require enhanced audits.

Why Organizations Use It

• Mandatory for NY-licensed financial firms to avoid multimillion fines (e.g., Robinhood $30M).
• Enhances resilience, reduces incident risk, builds stakeholder trust.
• Aligns with enterprise risk management for competitive edge.

Implementation Overview

• Phased roadmap: governance setup, risk assessment, controls rollout (MFA by 2025), evidence repository.
• Applies to banks, insurers, licensees in NY; scalable by size.
• No universal certification; NYDFS exams and annual filings required. (178 words)