What It Is

Federal Information Security Modernization Act (FISMA) is a U.S. federal law establishing a risk-based framework for protecting federal information and systems. Enacted in 2002 and modernized in 2014, it mandates agency-wide information security programs using the NIST Risk Management Framework (RMF) to ensure confidentiality, integrity, and availability.

Key Components

• NIST RMF 7 steps: Prepare, Categorize, Select, Implement, Assess, Authorize, Monitor.
• FIPS 199 categorization and NIST SP 800-53 controls (20 families, baselines by impact level).
• Continuous monitoring via SP 800-137, annual IG assessments, and CISA/OMB metrics.
• Compliance model emphasizes evidence-based ongoing authorization, not periodic certification.

Why Organizations Use It

FISMA drives mandatory compliance for federal agencies and contractors, reducing breach risks, enabling market access, and building stakeholder trust. It aligns cybersecurity with mission outcomes, offering efficiency through automation and competitive edge in federal procurement.

Implementation Overview

Follow RMF phases with governance setup, inventory, control deployment, assessments, and sustainment. Applies to federal executive agencies, contractors, cloud providers; scalable for large enterprises to smaller vendors via FedRAMP. Requires annual reporting and IG audits.

What It Is

23 NYCRR Part 500, the New York Department of Financial Services (NYDFS) Cybersecurity Regulation, is a state regulation establishing minimum cybersecurity standards for financial services entities. Its primary purpose is safeguarding nonpublic information (NPI) and ensuring operational integrity against cyber threats. It employs a risk-based approach with prescriptive elements, evolved through 2023 amendments emphasizing evidence-based compliance.

Key Components

• **14 core requirementsCybersecurity program, policy, CISO governance, access privileges, MFA, encryption, risk assessments, TPSP oversight, penetration testing, incident response, annual certification.
• Pillars include governance accountability, technical controls, vendor management, testing, and 72-hour reporting.
• Built on NIST CSF-aligned methodologies; requires CEO/CISO dual-signature annual certification with 5-year record retention.

Why Organizations Use It

• Mandatory for NY-licensed financial entities to avoid multimillion-dollar fines (e.g., Robinhood $30M).
• Drives cyber resilience, robust TPRM, incident readiness.
• Enhances stakeholder trust, reduces enforcement risk, aligns with enterprise risk management.

Implementation Overview

• Phased roadmap: gap analysis, risk assessment, control deployment (MFA, asset inventory), evidence repository.
• Targets NY-chartered banks, insurers; Class A companies face enhanced audits.
• No formal certification but NYDFS examinations enforce compliance. (178 words)