Why a checked box stopped working
A checked box is no longer an answer.
New York's Department of Financial Services requires every covered entity to develop, deploy, and maintain a cybersecurity program. Until recently, the Certification of Material Compliance was the finish line: log into the DFS portal, find your agency icon, check the boxes, done.
That era is over. DFS placed strict due diligence obligations on insurance carriers, and carriers are now pushing those obligations downstream to the agencies and aggregators selling their products. Questionnaires that once asked Yes or No now ask if yes, show us the evidence.
The gap is rarely the control. It is the document that proves the control was there — and that is what fails an examination. PCS closes that gap by design: every answer carries its evidence, its date, and the name of whoever accepted it.
23 NYCRR Part 500 · 42 sections · Second Amendment effective 1 November 2023