The New York Department of Financial Services (“Department”) has recently released Insurance Circular Letter No. 1 (2026) regarding disaster planning, preparedness, and response by the Property/Casualty insurance industry. The key highlights are as follows:
- This letter is applicable to all property/casualty insurers, financial guaranty insurers, mortgage guaranty insurers, title insurers, reciprocal insurers, captive insurers, and various New York regulatory bodies, as outlined in the circular letter (collectively, “addressees”).
- All addressees must submit a response to the Department’s pre-disaster data survey, available on the Department’s website.
- Each addressee should perform at least annually a business impact analysis to predict the consequences of disruption of any business function and process as a result of a disaster, and to gather information needed to develop recovery strategies.
- An addressee should use the results of this analysis to establish, maintain, and update a business continuity plan. Each addressee, other than a financial guaranty insurer, should perform at least annually a risk-based analysis of its capacity to assist customers in NY affected by a disaster occurring anywhere in the world, including NY, and should establish, maintain, and update a disaster response plan that takes into account the results of the analysis.
- The business continuity and disaster response plans should be separate documents.
- An addressee must track any changes to the disaster response plan since the last submission. If the current disaster response plan is the same as the last plan filed with the Department, then an addressee need not submit the plan again but must indicate in the portal application that the previously filed disaster response plan is still in effect.
- An insurer should notify the Department whenever the insurer activates, or intends to activate, a hurricane or windstorm deductible under any property/casualty insurance policy by sending an email to NYSInsuranceDisasterCoalition@dfs.ny.gov.
- As part of the New York Information Network, addressees’ CEOs, or their equivalent, should designate a primary and secondary intelligence or information officer, who should be senior-level executives with authority to communicate directly with the addressee’s CEO, using the form available on the Department’s website.
Please note that each addressee must submit a response to the pre-disaster data survey to the Department by June 11, 2026, and submit to the Department a disaster response plan, a response to the disaster response plan questionnaire, and a response to the business continuity plan questionnaire by July 30, 2026.