Numerous provisions that were subject to an 18-month transitional period for the New York Department of Financial Services’ Cybersecurity Regulation are now in effect, with companies looking ahead to daunting third-party rules that enter into force in March 2019. Certain provisions of the regulation, such as those presenting certification and audit trail issues, create program requirements that may not be obvious, experts told the Cybersecurity Law Report. This article details six of these and discusses the enforcement and compliance climate. See “Preparing to Meet the Deadlines of DFS’ Revised New York Cybersecurity Regulation” (Jan. 25, 2017).