DFS Partially Clarifies Who Qualifies for an Exemption Under Cybersecurity Regulation

By the terms of 23 NYCRR 500.19(e), Covered Entities that have determined they qualify for a limited exemption from compliance under 23 NYCRR 500.19(a)-(d) of New York’s new Cybersecurity Regulation — as of August 28, 2017 — are required to file a Notice of Exemption with the New York Department of Financial Services (NYDFS) on or prior to September 28, 2017. The first compliance date of August 28, 2017 in New York’s cybersecurity regulation, and the date for Covered Entities
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Principle Based Reserving Coming January 1, 2017

In recent years, life insurance companies have expressed concern that the current approach to product reserves does not take into account the increasingly complex, non-static, nature of current life insurance products. In response to these concerns, the National Association of Insurance Commissioners (NAIC) conducted “an extensive analysis of amended Standard Valuation Laws passed by 45 states, representing nearly 80 percent of the U.S. life insurance market.” The end result happened on June 10, 2016, when the National Association of Insurance
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NYDFS Has New Acting Superintendent

New York State Governor Andrew Cuomo recently named Shirin Emami as Acting Superintendent of the New York Department of Financial Services (NYDFS). She is the second acting superintendent since the resignation of Benjamin Lawsky, who left NYDFS in June 2015 for a private-sector position specializing in cyber security research and consulting. Ms. Emami replaces Anthony Albanese, who also left for the private sector. Prior to her appointment, Ms. Emami served as both the Executive Deputy Superintendent and the General Counsel
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