Papa Has a Brand New Bag
All in the Family – Introducing Family Owned Life Insurance™ (aka FOLI™)
TAKE A CHANCE ON ME! PART II - Embracing the Magic of Private Placement Life Insurance and Private Placement Variable Annuities
RETURN TO FOREVER - What Game Shall We Play Today?
NOWOTNY KNOWS SQUAT! Part IV Using Post-Retirement Medical Plans to Raise AUM and Sell Life Insurance
NOWOTNY ON DEATH AND TAXES EPISODE 35 USING POST-RETIREMENT MEDICAL PLANS TO RAISE AUM
NOWOTNY KNOWS SQUAT! Part 3 Using Malta Pension Plans to Raise AUM and Sell More Life Insurance
NOWOTNY KNOWS SQUAT! Part 2 Using PPLI and PPVA Annuities to Raise Assets Under Management and Sell More Life Insurance
INTRODUCING MALTA SPLIT DOLLAR
WHERE EAGLES DARE-INTRODUCING MALTA SPLIT DOLLAR
Private Placement Life Insurance Discussion Podcast
ISLA DEL ENCANTO - INTRODUCING BORICUA SPLIT DOLLAR
Isla del Encanto-Introducing Boricua Split Dollar
Everything You Need to Know About Beneficiary Designations
THE WONDER YEARS WEBINAR
HEAVEN CAN WAIT
On April 24, 2024, the New York State Department of Financial Services (NYDFS) published Proposed Rule Making for the 13th Amendment to Insurance Regulation 17, 20 and 20-A (Proposed Amendment), which purports to implement...more
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
We previously reported on regulators’ increased attention to the use of big data systems, including external consumer data and information sources, algorithms and predictive models. Recent announcements in Colorado, Louisiana...more
The New York Department of Financial Services (“NYDFS”) recently announced that it has entered into a Consent Order with two affiliated life insurers for alleged violations of New York’s Cybersecurity Regulation (the “NY...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
The New York Department of Financial Services has sent a letter to the institutions that it regulates requiring each such institution, by February 7, 2020, to provide to DFS a description of its “plan to address its LIBOR...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
New York’s amendment to Regulation 187 has gone into effect, more than a year after it was first proposed. Our Insurance Litigation & Regulation Group investigates the changes to the original amendment and how they affect the...more
The New York Department of Financial Services’ (DFS) January 2019 insurance circular letter, which advised New York-licensed life insurance carriers on the use of external consumer data and information sources in...more
To kick off the New Year, the New York Department of Financial Services (“DFS”) published Insurance Circular Letter No. 1 (2019) warning life insurers that use of external consumer data and information sources, commonly...more
On January 18, 2019, the New York Department of Financial Services (NYDFS) issued a circular letter to all insurers authorized to write life insurance in New York State setting out the Department’s views concerning the use of...more
The New York Department of Financial Services (“DFS”) recently released guidance describing how a life insurer may use so-called “external data,” that is, data not directly related to an applicant’s medical condition, without...more
Editor's Note - OCC to Accept FinTech Charters; Treasury Endorses “Regulatory Sandbox” to Encourage Financial Innovation. The Office of the Comptroller of the Currency (OCC) announced on July 31 that it would begin...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
Our Insurance Litigation & Regulation Group breaks down New York’s updated proposed first amendment to Regulation 187 that now affects sales of life insurance—not just annuity products—and what it means for insurance...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