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ARTICLE · 11 JUNE 2020

NY DFS Regulations Allow Superintendent To Be Group-Wide Supervisor

Herbert Smith Freehills Kramer LLP
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On June 3, amendments to New York insurance regulations, available here, became effective that will permit the New York Superintendent of Financial Services to act as group-wide supervisor of internationally active...

United StatesInsurance
Daniel Rabinowitz
Daniel Rabinowitz
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On June 3, amendments to New York insurance regulations, available here, became effective that will permit the New York Superintendent of Financial Services to act as group-wide supervisor of internationally active insurance groups (IAIGs, as defined below) having a specified New York nexus. Once so designated, such an entity would be subject to enhanced regulatory oversight by the superintendent.

Under these amendments to Department of Financial Services (DFS) Regulation 203 (11 NYCRR 82), adopted by Superintendent Linda A. Lacewell on June 3, an IAIG is, generally, (i) a holding company system (i.e., a New York-licensed insurer controlled by a holding company or other parent together with the insurer's affiliates), (ii) an Article 16 system (a New York-domiciled property-casualty insurer and its subsidiaries) or (iii) an Article 17 system (a New York-domiciled life insurer and its subsidiaries) (any of the foregoing, a "group" or an "insurance group") that meets

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