The National Association of Insurance Commissioners (NAIC) held its Fall 2020 National Meeting (Fall Meeting) December 3-9, 2020. As a result of the continuing COVID-19 pandemic, the NAIC once again met in a virtual format. This Sidley Update summarizes the highlights from this meeting in addition to interim meetings that were held during November in lieu of taking place during the Fall Meeting.
On July 21, 2020, the New York State Department of Financial Services (NYDFS or the Department) issued a statement of charges and notice of hearing (the Statement) against First American Title Insurance Company (First American) for violations of the Department’s Cybersecurity Requirements for Financial Services Companies, 23 N.Y.C.R.R. Part 500 (Cybersecurity Regulation or Regulation). The First American Statement of charges alleges six violations of the Cybersecurity Regulation and marks the Department’s first action pursuant to the Regulation, which is enforced by the recently created NYDFS Cybersecurity Division.1
NYDFS’s Statement seeks relief against First American, including civil monetary penalties and an order requiring First American to remediate any defined violations. Although the Statement does not include a calculation of the total penalty, the NYDFS explains that the civil monetary fines against First American are to be assessed pursuant to the Financial Services Law, which provides for a maximum civil monetary penalty of $1,000 per violation of the Regulation.2 Because First American’s violations included the exposure of millions of documents containing nonpublic information (NPI), the total penalty potentially could be substantial. The First American hearing is scheduled to occur on October 26, 2020, at the NYDFS.
The National Association of Insurance Commissioners (NAIC) held its Summer 2019 National Meeting (Summer Meeting) in New York City from August 3 to 6, 2019. The Summer Meeting was highlighted by the following activities.
The National Association of Insurance Commissioners (NAIC) held its Spring 2019 National Meeting (Spring Meeting) in Orlando, Florida, from April 6 to 9, 2019. This post summarizes the highlights from this meeting.
The National Association of Insurance Commissioners held its Summer 2017 National Meeting in Philadelphia, Pennsylvania from August 6 to 9, 2017. This Sidley Update summarizes the highlights from this meeting. (more…)