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Cadwalader, Wickersham & Taft LLP

Lasting Excellence June 2024 - Insurance Companies in NAV, CLOs and Rated Feeders: Where Are We Now

If you are confused about the current state of play of insurance companies investing in CLOs, rated feeder structures and other NAV based loans, we are here to help. Let’s start with the basics: the National Association of...more

Locke Lord LLP

New York Department of Financial Services Issues Guidance on Insurance Loss Mitigation ‎Tools and Services

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On May 23, 2024, the New York Department of Financial Services (the “Department”) issued Insurance Circular Letter No. 3 (the “Letter”). The Letter is addressed to “all insurers authorized to write property/casualty insurance...more

Faegre Drinker Biddle & Reath LLP

Artificial Intelligence Briefing: NYDFS Releases Proposed Circular on AI Use in Insurance Underwriting, Pricing

New York’s Department of Financial Services releases proposed guidance on AI and other data sources in insurance underwriting and pricing — and you’ll note plenty of influence from Colorado’s governance regulation and the...more

Kramer Levin Naftalis & Frankel LLP

SVB Disqualified as a Letter of Credit Provider for Reinsurance Credit

As of March 11, the Securities Valuation Office of the National Association of Insurance Commissioners (NAIC) has removed Silicon Valley Bank (SVB) from the list of approved banks (“qualified U.S. financial institutions,” or...more

McDermott Will & Emery

"Control" of Insurers: A Concept That Remains a Work in Progress

The concept of “control” of insurers received significant attention from state insurance regulators last year and will receive even more in 2023. We wrote a brief report in April 2022 following the New York Department of...more

McDermott Will & Emery

Climate Change Regulatory Update for US Insurers: August 2022

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This year started off with a surge of enthusiasm among US proponents of increased climate-related financial risk disclosure by insurers and others: - Soon after the late-2021 Conference of the Parties (COP) 26 event in...more

Sheppard Mullin Richter & Hampton LLP

Kentucky and Maryland Enact Insurance Data Security Laws

In April, Kentucky (HB 474) and Maryland (SB 207) adopted insurance data security legislation based on the National Association of Insurance Commissioners (NAIC) model law. A total of 15 states have adopted the NAIC Model...more

Kramer Levin Naftalis & Frankel LLP

New York Legislation Would Impose Group Capital Calculation Requirement

Parent companies of insurers doing business in New York would be required to file a “group capital calculation,” or GCC, with the Superintendent of Financial Services under legislation introduced in the state Senate on May 3,...more

McDermott Will & Emery

Climate Change Regulatory Update for US Insurers: April 2022

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If anyone believed that the US Securities and Exchange Commission’s (SEC) release of proposed climate change-related disclosure requirements last month might have been an isolated matter, of immediate importance only to the...more

McDermott Will & Emery

Climate Change Regulatory Update for US Insurers

After a variety of promises concerning climate change-related regulatory development activity last year, forward movement has been relatively slow. The leading exception has been the New York Department of Financial Services...more

Eversheds Sutherland (US) LLP

New York Department of Financial Services announces creation of new Climate Risk Division and issues guidance on managing the...

On November 3, 2021, the New York Department of Financial Services (DFS) announced the creation of a new Climate Risk Division (the Division) that is tasked with integrating climate risks into DFS’s supervision of regulated...more

Eversheds Sutherland (US) LLP

New York Department of Financial Services announces newly-created Climate Risk Division

On November 3, 2021, the New York Department of Financial Services (DFS) announced the creation of a new Climate Risk Division (the Division) that is tasked with integrating climate risks into DFS’s supervision of regulated...more

Eversheds Sutherland (US) LLP

COVID-19-related insurance regulatory developments

There continues to be significant regulatory activity related to the novel coronavirus (COVID-19) and its impact on the insurance industry, as well as claims for damages due to looting and vandalism following the recent civil...more

Eversheds Sutherland (US) LLP

New York Department of Financial Services proposes a trio of corporate governance and oversight rules for insurers

The New York Department of Financial Services (DFS) has proposed three new rules relating to corporate governance and oversight for New York insurers. The new rules would bring New York insurance laws in line with National...more

Locke Lord LLP

Cybersecurity Update: NYDFS, NAIC, and What’s Going on in SC, OH, MI, and MS?

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On March 1, 2017 the cybersecurity regulation of the New York Department of Financial Services (the “DFS Regulation”) took effect, requiring subject financial institutions, including insurance companies, (“Covered Entities”)...more

Carlton Fields

As Students Return to School, Regulators Continue Their Study of the NAIC’s Suitability in Annuity Transaction Model Regulation

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At the 2018 NAIC Summer National Meeting, regulators continued their efforts to define the standard of care that applies to recommendations. This subject was discussed at both the Annuity Suitability (A) Working Group...more

Locke Lord LLP

Follow the Leader: NYDFS Cybersecurity Regulation Leads the Way for Other States and Industries

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The New York Department of Financial Services (NYDFS) blazed a cybersecurity trail with its 2017 regulation for the protection of information collected and processed in, and systems used in the operation of, the financial...more

Carlton Fields

In The Duty Of Care Race, The NAIC Is In The Chase With New Proposed Revisions To Its Annuity Suitability Model

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On July 24, in preparation for its August 4 meeting at the NAIC 2018 Summer National Meeting, the Annuity Suitability (A) Working Group (the “Suitability WG”) peddled fast and released a working draft of proposed revisions...more

White and Williams LLP

South Carolina’s New Insurance Data Security Act: Pebbles Before a Landslide?

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The ramp-up of cybersecurity regulation, albeit in a patchwork fashion through state-level legislation, has begun. On May 18, 2018, South Carolina enacted the Insurance Data Security Act (Act), becoming the first state to...more

Carlton Fields

Expect Focus - Volume IV, December 2017

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EXPECTFOCUS is a quarterly review of developments in the insurance and financial services industry, provided on a complimentary basis to clients and friends of Carlton Fields Jorden Burt, P.A. ...more

Carlton Fields

The NAIC Says Aloha

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The National Association of Insurance Commissioners held its Fall National Meeting December 2-4 in Hawaii, saying aloha to 2017 and aloha to 2018. Key takeaways include...more

Carlton Fields

New York Department of Financial Services Rings in the New Year with New Suitability Requirements for Insurance Companies

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New York’s Department of Financial Services decided to bid farewell to 2017 and ring-in the new year by proposing to amend Suitability in Annuity Transactions, 11 NYCR 224 (the Annuity Suitability Rule). On December 27, 2017,...more

Locke Lord LLP

Developing Cybersecurity Requirements in Banking, Insurance and Other Financial Services

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The financial services industry has been dealing with requirements for cybersecurity since 1999, but 2017 brought new, significant, and proliferating obligations. The bar for the whole industry was clearly raised by the...more

Mintz - Privacy & Cybersecurity Viewpoints

Insurance Commissions Approve Data Security Model Law

The National Association of Insurance Commissioners (NAIC) has approved its draft of the Insurance Data Security Model Law (Model Law) via a meeting of its Executive and Plenary Committees. This important development follows...more

Locke Lord LLP

Forward Vision: New York’s Cybersecurity Regulation Imposes a Series of Deadlines

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New York’s cybersecurity regulation that went into effect in March has far reaching implications. The first transition date for implementation of several requirements of the state’s Department of Financial Services regulation...more

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