New York Developments

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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.…

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. ‎…

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.…

On Tuesday, January 25th, the New York State Senate voted to confirm Adrienne Harris as Superintendent of the New York State Department of Financial Services (the “NY DFS”).  Harris had served as acting superintendent of the NY DFS since being nominated for the full-time position by Gov. Kathy Hochul in August of 2021.…

On December 7, 2021, the New York Department of Financial Services (“NY DFS”) released an industry letter providing guidance on Multi-Factor Authentication (“MFA”).   MFA, which requires users of information systems to provide an additional “factor,” often through a one-time code or push notification to their mobile device, in addition to their password when accessing information systems.…