FedRAMP
U.S. program standardizing federal cloud security assessments
23 NYCRR 500
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.
FedRAMP
Federal Risk and Authorization Management Program
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
23 NYCRR 500
23 NYCRR Part 500
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
| Aspect | FedRAMP | 23 NYCRR 500 |
|---|---|---|
| Scope | Cloud security assessment, authorization, monitoring | Financial services cybersecurity program, governance |
| Industry | US federal government cloud providers | NY financial services entities (banks, insurers) |
| Nature | Standardized authorization program, mandatory for federal | State regulation, mandatory for covered entities |
| Testing | 3PAO assessments, annual reassessments, continuous monitoring | Annual pen testing, bi-annual vulnerability scans |
| Penalties | Loss of authorization, procurement exclusion | Fines, consent orders, license actions |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about FedRAMP and 23 NYCRR 500
FedRAMP FAQ
23 NYCRR 500 FAQ
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