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NYDFS Issues Proposed Guidance on AI and External Consumer Data Use

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

"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

Insurance Regulators Continue Big Data Scrutiny

We previously reported on regulators’ increased attention to the use of big data systems, including external consumer data and information sources, algorithms and predictive models. Recent announcements in Colorado, Louisiana...more

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

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

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

NYDFS—First Enforcement Action under Cybersecurity Regulation

On July 21, 2020, the New York Department of Financial Services (NYDFS) announced that it had filed its first enforcement action under 23 NYCRR 500 (the “Cybersecurity Regulation”) against First American Title Insurance (the...more

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