Automating Regulatory Governance: A DevOps-Centric Framework for Secure Large-Scale Data Migration under NYDFS 23 NYCRR 500

Abstract

With the increasingly adopted on-premise mainframe systems in the financial services industry shifting towards the distributed public clouds infrastructures, the issue of keeping pace with the strict cybersecurity requirements has become an essential operational issue. The current study presents a novel Compliance-by-Design (CbD) model that was designed to overcome the systemic complexities of the large data migration in accordance with the New York Department of Financial Services (NYDFS) 23 NYCRR 500 regulation. The methodology under consideration combines DevOps automation and advanced Data Engineering protocols, where the regulatory requirements are directly implemented into the data lifecycle by using Infrastructure-as-Code (IaC). One of the technical contributions made is the orchestration of automated encryption-at-rest triggers (Section 500.15) and serverless data retention and disposal lifecycle policies (Section 500.13). The model was tested with a massive migration of more than 100 million records of sensitive non-public information (NPI) of a Tier-1 American insurer. Quantitative data prove the security misconfigurations caused by human error is decreased by 98.3 percent and the number of audit readiness is four times more, and the time spent on compliance preparation decreased to less than 4 hours instead of 240 hours. The framework will enable the creation of a scalable blueprint on how to attain regulatory integrity in a cloud-native age by transitioning the current manual audit-based governance to a more continuous and integrated CI/CD framework.