NY Regulation 187 - NYDFS Issues Subsequent Guidance

On July 18, 2018, the New York Department of Financial Services (“NYDFS”) issued its final amendments to Regulation 187 which are applicable to annuity as well as life insurance products.

The new Regulation 187became effective for annuity products on August 1, 2019 and is effective for life insurance products on February 1, 2020.

The new Regulation 187 is called “Suitability and Best Interests in Life Insurance and Annuity Transactions.”

The revisions to Regulation 187 introduce a best interest standard applicable to both annuities and life insurance products.  The introduction of suitability and best interest standards applicable to life insurance products will require life insurers to develop appropriate compliance strategies to address these new requirements.

The NY DFS issued subsequent guidance, as follows:

CEFLI will continue to monitor developments pertaining to Regulation 187 compliance strategies over the months ahead.