Standards Comparison

    Basel III

    Mandatory
    2010

    Global framework strengthening bank capital, leverage, liquidity standards

    VS

    23 NYCRR 500

    Mandatory
    2017

    NY regulation for financial services cybersecurity.

    Quick Verdict

    Basel III sets global bank capital/liquidity rules for financial stability, while 23 NYCRR 500 mandates cybersecurity for NY firms. Banks adopt Basel for solvency; NY entities comply with 500 to avoid fines and protect data.

    Financial Risk Management

    Basel III

    Basel III: Finalising post-crisis reforms

    Cost
    €€€
    Complexity
    Medium
    Implementation Time
    18-24 months

    Key Features

    • 4.5% CET1 minimum with stricter capital quality
    • 3% non-risk-based leverage ratio backstop
    • LCR requiring 100% HQLA for 30-day stress
    • NSFR mandating stable funding over one year
    • Capital buffers restricting payouts when breached
    Financial Services

    23 NYCRR 500

    23 NYCRR Part 500 Cybersecurity Regulation

    Cost
    €€€€
    Complexity
    High
    Implementation Time
    18-24 months

    Key Features

    • Annual CEO/CISO compliance certification
    • 72-hour cybersecurity incident notification
    • Phishing-resistant MFA for high-risk access
    • Comprehensive TPSP risk management policy
    • Risk-based penetration testing and vulnerability assessments

    Detailed Analysis

    A comprehensive look at the specific requirements, scope, and impact of each standard.

    Basel III Details

    What It Is

    Basel III is the global regulatory framework issued by the Basel Committee on Banking Supervision (BCBS) post-2007-2009 financial crisis. It sets prudential standards for banks, focusing on enhancing capital quality, constraining leverage, and ensuring liquidity resilience through a multi-metric "belts and suspenders" approach combining risk-based and non-risk-based measures.

    Key Components

    • **Pillar 1Minimum capital ratios (CET1 4.5%, Tier 1 6%, Total 8%), leverage ratio (3%), LCR (100% HQLA for 30-day stress), NSFR (stable funding over one year), plus buffers (CCB 2.5%, CCyB up to 2.5%, G-SIB/D-SIB).
    • **Pillar 2Supervisory review via ICAAP and stress testing.
    • **Pillar 3Standardized disclosures for RWA comparability (e.g., KM1, LR1, CDC templates). Built on three-pillar structure with output floor constraining internal models.

    Why Organizations Use It

    Banks adopt Basel III for regulatory compliance, as jurisdictions implement it via domestic law. It boosts resilience, reduces systemic risk, improves market discipline, and shapes asset allocation and funding strategies. Enhances competitiveness through credible buffers and transparency.

    Implementation Overview

    Phased multi-year rollout via gap analysis, data architecture upgrades, model validation, and governance. Applies to internationally active banks globally; requires internal processes, no formal certification but supervisory assessments and Pillar 3 reporting. (178 words)

    23 NYCRR 500 Details

    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. It establishes minimum risk-based cybersecurity requirements to protect nonpublic information (NPI) and information systems. The approach is prescriptive yet tailored via documented risk assessments.

    Key Components

    • 14 core requirements including cybersecurity program, CISO governance, MFA, encryption, access privileges, TPSP oversight, penetration testing, incident response, and annual certification.
    • Built on risk assessment foundation (NIST CSF or equivalent); dual CEO/CISO annual certification with 5-year record retention.
    • Class A companies face enhanced controls like independent audits and EDR.

    Why Organizations Use It

    • Mandatory for NY-licensed financial entities (banks, insurers, etc.) to avoid multimillion-dollar fines (e.g., Robinhood $30M).
    • Enhances resilience, reduces incident risk, builds stakeholder trust, lowers insurance premiums.

    Implementation Overview

    • Phased roadmap: governance setup, risk assessment, technical controls (MFA by 2025), TPSP contracts, testing.
    • Applies to Covered Entities in NY financial sector; no certification but annual filing and DFS examinations.

    Key Differences

    Scope

    Basel III
    Bank capital, leverage, liquidity standards
    23 NYCRR 500
    Cybersecurity program, MFA, incident response

    Industry

    Basel III
    Global banking sector
    23 NYCRR 500
    NY financial services entities

    Nature

    Basel III
    Global prudential standard, implemented nationally
    23 NYCRR 500
    Mandatory NY state regulation

    Testing

    Basel III
    Pillar 2 stress tests, ICAAP reviews
    23 NYCRR 500
    Annual pen testing, vulnerability scans

    Penalties

    Basel III
    Supervisory capital add-ons, restrictions
    23 NYCRR 500
    Fines, consent orders, license actions

    Frequently Asked Questions

    Common questions about Basel III and 23 NYCRR 500

    Basel III FAQ

    23 NYCRR 500 FAQ

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