DFS coverage and shared services
Part 500 depends on qualifying financial-services authorization. Review licenses, exemptions, Class A criteria and affiliate boundaries.
NYDFS, utility IT & customer privacy
Plan a utility cybersecurity and privacy audit with separate DFS, PSC and personal-information tracks. Define the entity, examine evidence and carry findings through verified closure.

Part 500 depends on qualifying financial-services authorization. Review licenses, exemptions, Class A criteria and affiliate boundaries.
Part 1200 and existing PSC PII orders require their own jurisdiction, size, ownership and transition decisions.
Review SHIELD safeguards, breach roles, resident information and state or local notification procedures.
Plan evidence, samples, field permissions, findings, corrective actions and verified handover.
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Planning edition: October 15, 2026. New York adopted utility IT cybersecurity rules in April 2026, effective June 1, with phased requirements. Utility status alone does not establish NYDFS coverage.
Use the final PSC adoption and Appendix A, the State Register adoption notice, the DFS resource center and the current GBL breach statute, safeguards statute and state/local notification provisions.
The review report identifies apparent drafting errors, first-year timing questions and unavailable entity-specific criteria. Obtain current utility orders, tariffs, local policies and written clarification before adopting conclusions. The pack is a planning resource; completed work requires actual evidence and approvals.
Bring the entity profile and unresolved questions to a scoped planning discussion. Keep completed worksheets and evidence in controlled records.