Changes Are Coming To the Cybersecurity Regulation

You may have received an email message from DFS announcing the proposed changes. That message informed recipients that they may provide comments to the department between now and Jan. 9, 2023.The 20-page proposal closely resembles a pre-proposal draft DFS published last July. Big I New York provided comments to the department in response, and DFS appears to have taken some of our comments into consideration as they wrote the formal proposed amendments.Many of the amendments are targeted toward larger “covered entities” (the regulation’s term for any person or organization licensed under the state’s banking, financial services or insurance laws,) such as insurance carriers and banks.…

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Regulation 187: A Fight Worth Fighting, Despite a Disappointing Ruling

​What Happened:For the past four years, Big I NY has been fighting a legal challenge against the New York Department of Financial Services (“DFS") concerning Amended Insurance Regulation 187. The Amended Regulation 187 requires the “Producer" to act in the “Best Interests" of the customer. It also requires that the Producer make a “suitability" “recommendation" based on an analysis of their “needs." In our view, the regulation is unfairly vague and extremely challenging for producers to comply with. We remain concerned that this will lead to reduced access to the trusted advice consumers deserve. In 2021, the Appellate Court, 3rd Department, unanimously ruled in our…

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