NY| NYDFS Circular Letter No. 2 (2026) ets updated DFS expectations for life and health insurers’ disaster planning, requiring robust, board‑approved business continuity and disaster response frameworks, timely data support to DFS during events, and formalized liaison and information‑sharing roles.
Key Points:
- Insurers and specified health entities must conduct annual business impact and risk analyses, maintain separate but coordinated business continuity and disaster response plans scaled to their operations, and ensure off‑site, accessible storage and regular testing with corrective action.
- By July 30, 2026, addressees must file a disaster response plan and responses to DFS disaster response and business continuity questionnaires via the DFS portal (using DFS ID), with an officer affirmation under penalty of perjury and evidence of board or governing body approval.
- After a disaster, designated disaster liaisons must staff DFS’s Insurance Emergency Operations Center, supply ongoing coverage and claims data to support state and federal disaster decisions, and maintain New York Information Network contacts to receive and relay terrorism‑related intelligence and other sensitive information.