WHERE HAVE YOU GONE, CHIP HILTON?
Somewhere Over the Rainbow
Investment Management Roundtable Discussion – Personal Estate Planning
Regulators Hit Jackpot: Off-Channel Communications - Several years before announcing the first “off-channel” communications enforcement action, the SEC and FINRA cautioned broker-dealers and investment advisers about...more
Worried that the cards may be stacked against certain consumers and producers, the New York Department of Financial Services (DFS) released a circular letter and filing guidance note on July 17 to remind insurers of their...more
Earlier this week, the New York Department of Financial Services (“DFS”) published Circular Letter No. 6 (2023) identifying activities by life insurance and annuities providers that it views as being unlawfully discriminatory...more
New guidance from the New York Department of Financial Services (DFS) takes aim at improper discrimination by life and annuity writers in the state. DFS Insurance Circular Letter No. 6, issued on July 17, explains that New...more
On July 17, 2023, the New York Department of Financial Services (DFS) issued Insurance Circular Letter No. 6 (2023) (“Letter No. 6”) and a concurrent press release seeking to clarify, and in our opinion repeal, earlier...more
Insurers writing variable annuities in New York will want to focus on newly proposed requirements from the New York Department of Financial Services (DFS) on separate account contracts...more
New York-licensed insurers that write life and annuity products should consider possible balance-sheet implications for in-force variable business — including the ability to establish certain reserves over five years...more
Legislation proposed as part of Gov. Andrew Cuomo’s executive budget for 2021 would substantially expand the enforcement powers of the superintendent of the New York State Department of Financial Services, as well as the...more
It appears that the SEC has initiated a “sweep” examination to inquire into the sales practices applicable to retirement plans for teachers and state and local government employees. We understand that multiple SEC regional...more
With M&A activity for life insurers or blocks of in-force business poised for a possible spike, acquirers of life businesses should consider factors that are peculiar to, or disproportionately affect, the life and annuity...more
On July 18, 2018 Maria T. Vullo, New York Financial Services Superintendent, announced the adoption of certain amendments to Insurance Regulation 187, which requires insurers to establish standards and procedures for agent...more
On July 18, New York's Department of Financial Services (the "NY DFS") issued the final version of its Suitability and Best Interests in Life Insurance and Annuity Transactions Regulation (the "Suitability and Best Interest...more
Effective August 1, 2019, the New York Department of Financial Services has amended and renamed New York Insurance Regulation 187, which will now be called “Suitability and Best Interests in Life Insurance and Annuity...more
On April 27, New York's Department of Financial Services (NY DFS) issued its updated proposed First Amendment (Updated First Amendment) to New York's Suitability in Annuity Transactions, 11 NYCR 224 (the Annuity Suitability...more
On December 27, 2017, the New York Department of Financial Services (NYS-DFS), the regulatory authority for the insurance industry in New York, published a proposal (New York Proposal) to add a “best interest” standard to...more
New York’s Department of Financial Services decided to bid farewell to 2017 and ring-in the new year by proposing to amend Suitability in Annuity Transactions, 11 NYCR 224 (the Annuity Suitability Rule). On December 27, 2017,...more
The clock is ticking on the New York Department of Financial Services’ issuance of new Regulation 210 "Life Insurance and Annuity Non-Guaranteed Elements" (the Rule). ...more
On September 19, the New York Department of Financial Services promulgated the final version of new Regulation 210 “Life Insurance and Annuity Non-Guaranteed Elements” (the “Rule”).The Rule takes effect on March 19, 2018....more
Last week, the New York Department of Financial Services (“NYDFS”) promulgated a new regulation 11 NYCRR 48, aimed at limiting the amount by which life insurance premiums can be raised as to policies issued in the state. In...more
On December 8, 2016, the New York State Department of Financial Services (the “Department”) issued a Circular Letter to provide guidance in response to the alleged failure of certain life insurance producers and life insurers...more
On November 17, the New York Department of Financial Services (DFS) issued a press release announcing its proposal of new Insurance Regulation 210 - Life Insurance and Annuity Non-Guaranteed Elements. Non-guaranteed elements...more
- AXA Prevails at First Post-Jones v. Harris Excessive Fee Trial - Potential Secondary Effects of Regulatory Examinations: Evidentiary Issues and Preclusion in Parallel Litigation - On The Horizon: Global...more