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McDermott Will & Emery

NYDFS Issues Proposed Guidance on AI and External Consumer Data Use

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On January 17, 2024, the New York State Department of Financial Services (NYDFS) issued a proposed Circular Letter that provides guidance for authorized insurers using external consumer data and information sources (ECDIS)...more

Harris Beach PLLC

Recent New York Cybersecurity Enforcement Provides Latest Reason for Companies to be Proactive

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New York’s Department of Financial Services signaled once again its intent to strongly enforce the state’s Cybersecurity Regulation by finding OneMain Financial Group violated the law in several ways and imposing a $4.25...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

NAIC Continues to Refine Multiyear Work Plan to Expand Scrutiny of Holding Company Act Filings

In our report published on April 26, 2022, we discussed the New York Department of Financial Services’ (NYDFS) Circular Letter No. 5 in which it reminded the industry that acquiring less than 10% of an insurer’s voting...more

McDermott Will & Emery

New York Says Less Than 10% Ownership Is Not a Safe Harbor

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On April 19, 2022, the New York Department of Financial Services (NYDFS) issued Circular Letter No. 5, reminding owners and potential purchasers of shares of insurance companies that acquiring less than 10% of the company’s...more

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