NY| New York DFS Circular Letter No. 1 (2026) replaces Circular Letter No. 3 (2025) and establishes comprehensive standards for disaster planning, preparedness, and response by property/casualty insurers and related entities, requiring them to submit pre-disaster data surveys for key lines, maintain and annually approve separate business continuity and disaster response plans scaled to their operations, file these plans and questionnaires via the DFS portal with officer attestations, support DFS’s Insurance Emergency Operations Center by designating disaster liaisons and providing ongoing post-disaster coverage and loss data, and participate in the New York Information Network through designated intelligence officers to facilitate rapid, secure communication of terrorism-related and other critical information.
Key Points:
- Scope and purpose: Applies to a wide range of property/casualty insurers and related organizations, repeals and replaces Circular Letter No. 3 (2025), and aims to ensure they can continue operations and serve New Yorkers during disasters anywhere in the world.
- Pre-disaster data survey: Certain insurers writing specified property and auto physical damage lines must submit county-level exposure and policy count data by June 11, 2026, to enable DFS and state emergency management to identify major writers and plan catastrophe response, including adjuster access.
- Business continuity and disaster response plans: Addressees must conduct at least annual business impact and capacity analyses and maintain separate, board- or governing body–approved business continuity and disaster response plans with detailed governance, recovery, communication, and testing provisions, with flexibility for group-level or captive arrangements if they adequately address the entity’s needs.
- Filing and post-disaster operations: By July 30, 2026, entities must file their plans and related questionnaires through the DFS portal with officer attestations under Insurance Law Section 308, keep filings current, support DFS’s Insurance Emergency Operations Center via designated disaster liaisons, provide ongoing post-disaster claim and coverage data, and understand the framework for temporary independent adjuster permits and activation of hurricane/windstorm deductibles.
- New York Information Network (NYIN): Insurers must maintain primary and secondary senior-level intelligence or information officers for terrorism-related and other sensitive communications through NYIN to ensure secure, direct channels between DFS and company leadership for critical threat information.