January 27th, 2017
Dear Superintendent Vullo:
The Electronic Transactions Association (“ETA”) appreciates this opportunity to provide comments on the New York State Department of Financial Services (“Department”) proposed Cybersecurity Rules for Financial Services Companies (23 NYCRR 500) (the “Proposal” or “Rule”).
ETA is the leading trade association for the payments industry, representing nearly 550 companies worldwide involved in electronic transaction processing products and services. The purpose of ETA is to influence, monitor, and shape the payments industry by providing leadership through education, advocacy, and the exchange of information. ETA’s membership spans the breadth of the payments industry, and includes financial institutions, payment processors, independent sales organizations, and equipment suppliers. ETA’s members use data to provide a wide range of products and services designed to enhance and secure electronic transfers. Our members rely on data to help reduce fraud and to authenticate transactions to make transactions between businesses and consumers seamless and secure.