DFS Superintendent Vullo Issues Updated Disaster Response and Recovery Plan Requirements for Insurers
Financial Services Superintendent
"When disaster strikes, as it did when Hurricanes Maria and Irma devastated
When a disaster occurs in
In the two updated circular letters issued today, DFS advised insurers of their disaster related obligations under
In addition to filing a disaster response and recovery plan, insurers must have a business continuity plan and regularly perform a business impact analysis to predict the consequences of disruption of a business function. The guidance issued today clarifies the requirements of the business analysis. It should identify the operational and financial impacts resulting from the disruption of business functions and processes, and include, at a minimum, the following:
* The point in time when a business interruption would have a greater impact, such as a particular season or the end of the month or quarter;
* The amount of time before which the business interruption would have an operational or financial impact;
* The operational and financial impact of physical damage to buildings; damage to or breakdown of machinery, systems, or equipment; restricted access to a site or building; a utility outage; damage to or loss or corruption of information technology; and absenteeism of essential employees;
* Resources needed for the business to continue to function at varying levels of disruption; and
* The potential for dissatisfaction or defection by policy owners, policyholders, contract holders, insureds, annuitants, payees, beneficiaries, third-party claimants, and health service providers.
The circular letters outline what an insurer's business continuity plan should, at a minimum, include, such as:
* Defining the scope, objectives, and assumptions of the business continuity plan;
* Defining the roles and responsibilities of employees;
* Identifying the lines of authority, succession of management, and delegation of authority;
* Addressing interaction with external business entities, including contractors and vendors;
* Including results of a business impact analysis;
* Identifying recovery time objectives for business processes and information technology;
* Identifying the recovery point objective for data restoration;
* Setting forth detailed procedures, resource requirements, and logistics for execution of all recovery strategies.
Following a disaster, the DFS Superintendent, in accordance with the nature and extent of the disaster, will activate the Department's
Electronic templates for responses to the pre-disaster survey and disaster response plan and business continuity plan questionnaires, and instructions for their completion and submission, are available on the DFS website at: http://www.dfs.ny.gov/insurance/iindx.htm#dpr.
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