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New York State Department of Financial Services orders insurance companies to submit business continuity information

The New York State Department of Financial Services (DFS) has directed insurance companies to submit their disaster response and recovery plans to the organization. DFS Financial Services Superintendent Maria T. Vullo announced that all insurance companies licensed to conduct business in New York State must submit updated disaster response and recovery plans and responses to online questionnaires by June 16, 2017.  Property/casualty companies are also being directed to file responses to the DFS Pre-Disaster Data Survey by April 28, 2017.  

“It is important for all insurers, whatever the scale of their business, to understand that their ability to recover from a disaster ultimately impacts the needs of New York consumers,” said Vullo.  “Disaster response and business continuity plans should reflect the nature, scale and complexity of each insurer’s business and these plans need to be updated at least annually.”

DFS issued two circular letters advising the insurers of their disaster related obligations under New York’s Insurance Law. The first circular letter was directed to property/casualty insurers, including such lines of business as mortgage guaranty insurance, title insurance and captive insurance. The second circular letter was directed to life insurers, as well as such entities as health insurers, fraternal benefit societies and employee welfare funds.
In addition to filing a disaster response and recovery plan, an insurer must have a business continuity plan.  The circular letters outline what an insurer’s business continuity plan should, at a minimum, include, including:

  • Defining the roles and responsibilities of employees designated to perform disaster-related functions;
  • Identifying lines of management authority;
  • Distributing and maintaining copies business continuity and disaster response plans. Copies of plans should be stored at secure off-site locations which allow access if a company’s computer servers are disabled.
  • Reporting results of a business impact analysis;
  • Identifying recovery time objectives for business processes and information technology;
  • Creating detailed procedures, resource requirements, and logistics for relocation to alternate worksites; and
  • Setting forth detailed procedures, resource requirements, and a data restoration plan for the recovery of information technology, such as networks and required connectivity, servers, computers, wireless devices, applications, and data.

Electronic templates for responses to the pre-disaster survey and disaster response plan and business continuity plan questionnaires, and instructions for their completion and submission, are available at

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