Standards Comparison

    FedRAMP

    Mandatory
    2011

    U.S. program standardizing federal cloud security assessments

    VS

    23 NYCRR 500

    Mandatory
    2017

    NY regulation for financial services cybersecurity compliance

    Quick Verdict

    FedRAMP standardizes secure cloud authorizations for US federal agencies, enabling reusable assessments. 23 NYCRR 500 mandates comprehensive cybersecurity programs for NY financial entities with strict governance and reporting. Organizations pursue FedRAMP for federal contracts; Part 500 for regulatory compliance.

    Cloud Security

    FedRAMP

    Federal Risk and Authorization Management Program

    Cost
    €€€
    Complexity
    Medium
    Implementation Time
    12-18 months

    Key Features

    • Reusable authorizations via assess-once-use-many-times model
    • NIST SP 800-53 Rev5 baselines at Low/Moderate/High levels
    • Independent assessments by accredited 3PAOs
    • Continuous monitoring with monthly deliverables and automation
    • FedRAMP Marketplace for agency reuse and transparency
    Financial Services

    23 NYCRR 500

    23 NYCRR Part 500

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

    Key Features

    • Annual CISO/CEO dual-signature compliance certification
    • 72-hour cybersecurity incident notification to NYDFS
    • Phishing-resistant MFA for privileged and remote access
    • Comprehensive TPSP risk management and contracts
    • Annual penetration testing and vulnerability assessments

    Detailed Analysis

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

    FedRAMP Details

    What It Is

    FedRAMP (Federal Risk and Authorization Management Program) is a U.S. government-wide framework standardizing security assessment, authorization, and continuous monitoring for cloud services used by federal agencies. Its primary purpose is enabling secure, efficient cloud adoption through reusable authorizations, based on a risk-based approach aligned with NIST SP 800-53 Rev 5 controls and FIPS 199 impact levels (Low, Moderate, High).

    Key Components

    • Baselines with ~156/323/410 controls for Low/Moderate/High impacts, plus LI-SaaS subset.
    • Core artifacts: System Security Plan (SSP), Security Assessment Report (SAR), Plan of Action & Milestones (POA&M).
    • Built on NIST standards; compliance via Agency or Program Authorizations.
    • Emphasizes 3PAO independent assessments and OSCAL machine-readable formats.

    Why Organizations Use It

    Cloud service providers (CSPs) pursue FedRAMP for federal market access, as agencies must use authorized services. It reduces duplication, enhances security posture, builds trust, and differentiates competitively. Enables reuse across agencies, mitigating legal risks in procurement.

    Implementation Overview

    CSPs categorize systems, prepare SSPs, engage 3PAOs for assessments, remediate via POA&Ms, and maintain continuous monitoring. Targets CSPs serving U.S. federal agencies; involves high costs ($150k-$2M+), long timelines (10-19 months), and annual reassessments.

    23 NYCRR 500 Details

    What It Is

    23 NYCRR Part 500 is the New York Department of Financial Services (NYDFS) cybersecurity regulation for financial entities. It establishes minimum risk-based cybersecurity standards to protect nonpublic information (NPI) and information systems' confidentiality, integrity, and availability. The approach is hybrid: prescriptive controls with risk assessment tailoring.

    Key Components

    • 14 core requirements including cybersecurity program, CISO appointment, MFA, encryption, TPSP oversight, penetration testing, incident response.
    • Annual CISO/CEO dual-signature certification by April 15, with 5-year record retention.
    • Built on risk assessments informing all controls; Class A companies face enhanced audits.
    • Compliance model emphasizes evidence-based attestation over third-party certification.

    Why Organizations Use It

    • Mandatory for NY-licensed financial services (banks, insurers, etc.), with multimillion-dollar enforcement penalties.
    • Reduces cyber incident risk, ensures operational resilience, builds stakeholder trust.
    • Strategic benefits: lowers insurance premiums, strengthens vendor negotiations, competitive edge in financial sector.

    Implementation Overview

    • Phased roadmap: governance setup, risk assessment, technical controls (MFA rollout), TPSP contracts, testing.
    • Applies to Covered Entities in NY financial services; scalable by size/complexity.
    • No formal certification; focuses on internal audits, annual filing, DFS examinations. (178 words)

    Key Differences

    Scope

    FedRAMP
    Cloud security assessment, authorization, monitoring
    23 NYCRR 500
    Financial services cybersecurity program, governance

    Industry

    FedRAMP
    US federal government cloud providers
    23 NYCRR 500
    NY financial services entities (banks, insurers)

    Nature

    FedRAMP
    Standardized authorization program, mandatory for federal
    23 NYCRR 500
    State regulation, mandatory for covered entities

    Testing

    FedRAMP
    3PAO assessments, annual reassessments, continuous monitoring
    23 NYCRR 500
    Annual pen testing, bi-annual vulnerability scans

    Penalties

    FedRAMP
    Loss of authorization, procurement exclusion
    23 NYCRR 500
    Fines, consent orders, license actions

    Frequently Asked Questions

    Common questions about FedRAMP and 23 NYCRR 500

    FedRAMP FAQ

    23 NYCRR 500 FAQ

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