Drafts a comprehensive Information Security Program compliant with NYDFS Cybersecurity Regulation (23 NYCRR 500). Covers CISO designation, risk assessment, access controls, encryption, monitoring, incident response, notification, and annual certification for covered financial services entities. Use when drafting cybersecurity programs, NYDFS compliance policies, or information security policies for financial institutions. Trigger keywords: NYDFS, 23 NYCRR 500, cybersecurity regulation, information security program, CISO policy, financial services cybersecurity.