New York Developments

Subscribe to New York Developments via RSS

Key Point: All businesses struggle with cybersecurity risks presented by their service providers. New guidance from the NY DFS applies to all DFS regulated entities, but the guidance would assist any business in any industry in addressing these risks.

On October 21, 2025, the New York Department of Financial Services (the “DFS”) issued important guidance for covered entities (including all DFS licensees) for managing their cybersecurity risk related to third-party service providers (“TPSPs”). Industry Letter – October 21, 2025: Guidance on Managing Risks Related to Third-Party Service Providers | Department of Financial Services specifically includes the covered entity’s use of cloud, file transfer, AI and fintech providers (“Guidance”). According to the DFS, the “Guidance does not impose new requirements or obligations . . ..” Rather, “it is intended to clarify regulatory requirements, recommend industry best practices . . ., and promote compliance . . ..” The Guidance highlights that managing the cybersecurity risk presented by TPSPs “remains a crucial element of a Covered Entity’s cybersecurity program,” and notes that it applies to all covered entities, regardless of size.Read More Important Guidance on Third-Party Service Provider Cyber Risk

On September 26, 2025, Governor Kathy Hochul of New York signed into law AB 5600 (the Bill), which amends N.Y. Ins. Law §7425 to address the treatment of voidable transfers involving Federal Home Loan Banks (FHLBs), as well as the conduct of parties to delinquency proceedings against New York domiciled insurer-members of an FHLB. FHLBs are government-sponsored entities that lend to members on a fully secured basis at a low interest rate. According to the legislative findings accompanying the Bill (the Legislative Findings), FHLBs were created during the Great Depression to provide easy liquidity for banks and insurance companies and to provide a stabilizing mechanism in times of economic uncertainty.[1] Insurance companies and depository institutions must apply for membership, subject to approval by the Federal Housing Finance Agency, and purchase a certain amount of stock in the FHLB to avail themselves of member benefits.[2]Read More New York Amends Voidable Transactions Law for Application to Federal Home Loan Banks

New York Governor Kathy Hochul announced today that Adrienne Harris will step down as superintendent of the New York State Department of Financial Services (NYDFS), effective October 18. Following Harris’s departure, Hochul has appointed Kaitlin Asrow to serve as acting superintendent.Read More NYDFS Announces Leadership Change: Adrienne Harris to Step Down, Kaitlin Asrow Named Acting Superintendent

What Happened

In a press release published August 25, New York Senators James Skoufis, Jamaal Bailey, and Brian Kavanagh announced a joint investigation into residential property insurance. The purpose of the investigation is “to identify the causes of reported increases in premiums and other obstacles to insuring new and existing single- and multi-family homes, including those occupied by homeowners and renters, and to identify legislation and policy changes that New York State should implement.”Read More New York Legislators Investigate Residential Property Insurance

On June 23, the New York State Department of Financial Services (NYDFS) issued an industry letter to all regulated entities — banks, insurers, money transmitters, virtual currency companies, and others — cautioning that escalating global conflicts are intensifying threats to the U.S. financial system. The letter highlights increased risk from destructive cyberattacks, sanctions evasion, and illicit activity involving virtual assets. NYDFS urges institutions to take immediate, proactive steps to strengthen operational resilience, ensure compliance, and protect the financial sector from geopolitical spillover.Read More NYDFS Warns of Heightened Risk From Global Conflicts: What Regulated Entities Must Do Now

Locke Lord’s Privacy & Cybersecurity Newsletter provides topical snapshots of recent developments in the fast-changing world of privacy, data protection and cyber risk management.
Read More December 2023 Privacy & Cybersecurity Newsletter: A Busy Year-End (States, EU, UK, Incident Response and Litigation)

Locke Lord’s Privacy & Cybersecurity Newsletter provides topical snapshots of recent developments in the fast-changing world of privacy, data protection, and cyber risk management. For further information on any of the subjects covered in the newsletter, please contact one of the members of our privacy and cybersecurity team.
Read More September 2022 Privacy & Cybersecurity Newsletter: Ch-ch-ch-changes – CA, NY DFS, and NFTs

On April 19, 2022, the New York Department of Financial Services (“NY DFS”) issued ‎Insurance Circular Letter No. 5 (2022) (the “Letter”). The Letter, entitled “Acquisitions of ‎Control and Disclaimers of Control”, was addressed to all New York domiciled insurers and ‎other interested parties. The purpose of the Letter is to remind insurance industry participates of ‎the requirements outlined under New York Insurance Code (“NY Ins. Code”) § 1506, which ‎requires NY DFS approval in connection with a change of control of an insurer. ‎…
Read More NY DFS Issues Circular Letter Addressing Acquisitions and Disclaimers of Control

Governor Kathy Hochul signed a bill that clarified the provisions recently allowing for commercial risk policies of less than one year under New York Insurance Law Section 3426. The original amendments, enacted in December 2021, provided generally that commercial risk policies of less than one year may be written if requested by the insured and offered by the insurer.
Read More New York Clarifies Provisions Allowing for Policies Under One Year

On December 22, 2021, New York State Governor Kathy Hochul signed Senate Bill S653A which amends the New York Insurance Law by adding Section 3458 regarding the electronic delivery of property and casualty insurance notices.
Read More New York State Law Regarding Electronic Delivery of Insurance Notices to Take Effect March 22