NY DFS to Impose New Limits on Variable Products

March 29, 2022 by Daniel Rabinowitz

Insurers writing variable annuities in New York will want to focus on newly proposed requirements from the New York Department of Financial Services (DFS) on separate account contracts. In guidance published on March 16 (Fourth Amendment to Regulation 47, 11 NYCRR 50, available here), DFS has proposed new rules for such products issued on or after Sept. 1, 2022 (referred to in this alert as New Issuances). With some key exceptions, the rules for New Issuances closely resemble existing DFS rules for separate account annuities; such existing rules, going forward, would apply only to contracts issued prior to Sept. 1, 2022 (Legacy Issuances).

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Originally Posted at JD Supra on March 25, 2022 by Daniel Rabinowitz.