Financial services

Your examiner does not accept good intentions.

Financial services organizations face the most demanding regulatory environment in any industry. NY DFS, GLBA, PCI DSS, SOX, and the new SEC cybersecurity rules demand documented, current, defensible evidence — not policies written in 2022 and a scan from last quarter.

Banks & Credit Unions Insurance Carriers Broker-Dealers RIAs Payment Processors Mortgage Companies Fintech
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Regulatory landscape

Five overlapping frameworks. One compliance program.

Most financial services firms are subject to multiple frameworks simultaneously. Pistos maps them all to a single CIS Controls v8.1 anchor — implement one control, satisfy every framework that requires it.

NY DFS 23 NYCRR Part 500

New York Department of Financial Services

The most comprehensive state cybersecurity regulation in the US. Requires a written cybersecurity program, annual penetration testing, CISO designation, board reporting, and annual Certification of Material Compliance. The 2023 amendment expanded requirements significantly — many firms filed certifications that do not reflect the amended requirements.

GLBA Safeguards Rule

Gramm-Leach-Bliley Act — FTC / Banking Regulators

Requires financial institutions to develop, implement, and maintain a comprehensive information security program. The 2023 updated Safeguards Rule added specific technical requirements — encryption, MFA, vulnerability assessment, and incident response — that many existing programs do not address.

PCI DSS v4.0

Payment Card Industry Data Security Standard

Any organization that processes, stores, or transmits payment card data must comply. Version 4.0 introduced customized implementation options and new requirements around targeted risk analysis, authentication, and web-based payment page security that took effect in March 2025.

SOX IT Controls

Sarbanes-Oxley Act — SEC / PCAOB

Public companies must maintain effective internal controls over financial reporting, which PCAOB auditors assess through IT General Controls — access control, change management, computer operations, and security. Deficiencies in IT controls are material weaknesses in financial reporting.

SEC Cybersecurity Rules

Securities and Exchange Commission — 2023

Public companies must disclose material cybersecurity incidents within four business days and provide annual disclosures about cybersecurity risk management, strategy, and governance. Board-level oversight of cybersecurity risk must be documented and disclosed.

NACHA Rules

ACH Network — Originating Depository Financial Institutions

ACH originators must maintain a written security framework, conduct annual risk assessments, and provide phishing simulation training for ACH-access staff. ODFI agreements require documented fraud detection standards and workforce competency records.

What examiners ask

The questions your examiner will ask. The answers Pistos prepares.

NY DFS examiners, OCC supervisors, and PCI QSAs ask the same questions in every examination. Pistos is built around producing exactly what they need — before they ask.

"Show me your annual risk assessment."

Documented annual risk assessment required by NY DFS 500.09 and GLBA.

Sentinel produces a complete risk assessment report with inherent risk ratings, control scores, and remediation roadmap.

"Who is your CISO and what do they do?"

NY DFS 500.04 requires a qualified CISO responsible for the cybersecurity program.

Aegis provides the designated CISO function with documented responsibilities and board reporting.

"Show me your training records."

Every framework requires documented training for all personnel.

Manthesis produces dated training completion records and phishing simulation results linked to each employee.

"What is your MFA coverage?"

NY DFS 500.12 requires MFA for all remote access and privileged accounts.

Skopein reads actual MFA enforcement state — not what the vendor reports, but what is actually configured.

"Show me your vendor risk assessments."

NY DFS 500.11 requires third-party service provider security policies.

Sentinel tracks vendor relationships and assessment status with evidence linked to each vendor record.

"Have you filed your annual certification?"

NY DFS requires annual Certification of Material Compliance by April 15.

Aegis prepares the certification supported by a complete, current Sentinel evidence record.

Your next examination starts today.

Request a briefing and we will map the Pistos platform to your specific NY DFS or GLBA examination requirements.

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