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ARTICLE · 04 JANUARY 2024

US NAIC Fall 2023 National Meeting Highlights: Cybersecurity (H) Working Group

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On November 16, 2023 the Cybersecurity (H) Working Group (the "Working Group") of the National Association of Insurance Commissioners ("NAIC") met virtually to discuss the following topics...

United StatesTechnology
Lawrence Hamilton
Lawrence Hamilton
Justin Herring
Justin Herring
Vikram Sidhu
Vikram Sidhu
Jared Wilner
Jared Wilner
Yuliya Feldman
Yuliya Feldman
Juliana G. Toes
Juliana G. Toes
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On November 16, 2023 the Cybersecurity (H) Working Group (the "Working Group") of the National Association of Insurance Commissioners ("NAIC") met virtually to discuss the following topics:

Cybersecurity Event Response Plan

The Working Group indicated that it will be circulating a revised draft of its Cybersecurity Event Response Plan ("CERP"), which is intended to govern multi-state coordination when multiple states are investigating a significant cyber incident occurring at an insurer. Notable revisions to the CERP which have been made by the Working Group include:

  • Introduction of a lead state concept: The Working Group noted that a lead state concept "may be an appropriate means of creating efficiency while still allowing states to gather information needed to support regulatory responses to cybersecurity events," and encouraged state departments of insurance ("DOIs") to use the lead state concept "where possible and appropriate."

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