A new report from the Ponemon Institute indicates that less than half of the nearly 600 financial institutions surveyed expect to meet the February 2018 deadline for certification of compliance with all of the cybersecurity rules from NY DFS that are applicable to them. Of those, nearly one-quarter said there was “no chance” they would be able to do so. Notwithstanding these challenges, the DFS has indicated on the FAQ section of its website that it expects covered entities to certify to “full compliance” with the applicable cybersecurity regulations by the deadlines, and that a firm may not submit a certification “unless the Covered Entity is in compliance with all applicable requirements of [the rule] at the time of certification.” We’ll continue to track developments in this area. In the meantime, you can click here to register for the full report.