Regulatory Compliance Consulting Firm

Westmont Wire

NYDFS Cyber Requirement Reminder

All Companies Regulated by the New York Department of Financial Services Are Required to Comply with Regulation’s Governance Policies and Procedures, as Well as Risk Based Monitoring Systems Requirements and Encryption Programs for Nonpublic Information by September 4, 2018


New York has reminded all regulated companies that the third transitional period for the New York cyber regulation ends on September 4, 2018. Starting September 4 all companies will be required to have:

  • Commenced mandatory annual reporting to the board by the Chief Information Security Officer concerning critical aspects of the cybersecurity program;
  •  An audit trail designed to reconstruct material financial transactions sufficient to support normal operations in the event of a breach;
  •  Policies and procedures in place to ensure the use of secure development practices for IT personnel that develop applications for the Covered Entity;
  •  Implemented encryption to protect nonpublic information held or transmitted by the company;
  • Developed policies and procedures to ensure secure disposal of information that is no longer necessary for the business operations; and
  •  Implemented a monitoring system that includes risk based monitoring of all persons who access or use any of the company’s information systems or who access or use the company’s nonpublic information.


The New York Department also reminds regulated entities that they utilize Third-Party Service Providers, they must evaluate the risk that any Third-Party Service Providers pose to the security of those systems and data and ensure those systems and data are protected by March 1, 2019.


Westmont Associates, Inc. tracks developments affecting the insurance industry, in addition to our other services.  If you have any questions, please contact us.

Connecticut Issues New Bulletin Regarding Stop Loss Policies

On August 1, 2018, the Connecticut Insurance Department issued Bulletin HC-120 rescinding and combining provisions from Bulletins HC-95 & PC-75 and HC-108 & PC-80.

The new Bulletin reaffirms that the claim liability limits in stop loss policies should not be set to a point that reaching the specific aggregate amount required to trigger the coverage is an actuarial certainty. Furthermore, the Bulletin highlights the current stop loss attachment point, coverage, and contract provision requirements related to stop loss policies.

Most importantly, Bulletin HC-120 authorizes the issuance of retiree health plans stop loss policies. Due to the magnitude of the risk associated with retiree health plan stop loss coverage, retiree health plans will not be subject to the aforementioned requirements and will instead be reviewed by the Department on a case-by-case basis.

For any questions regarding Bulletin HC-120, or for assistance in compliance matters pertaining to stop loss policies, please contact Westmont Associates, Inc.

Westmont on the Waterfront

Come Visit Westmont Associates, Inc. at the 111th Mid-Atlantic Mutual Advantage Convention!

Joseph Keller, Esq. and Katherine Lenguadoro of Westmont Associates, Inc. will be attending the Mid-Atlantic Mutual Advantage Convention August 5th through August 7th. If you would like to visit us during our time in the Charm City, please stop by Westmont’s booth to meet us. Westmont offers a full spectrum of insurance compliance and management services. Our seasoned professionals have a wealth of experience including but not limited to insurance company formation and licensing, agent/agency/MGA/TPA licensing, claims auditing and review, contract drafting, due diligence, and actuarial services. They are well versed in the handling of all manner of claims such as asbestos, environmental, workers’ compensation, surety, professional liability and property claims. Our staff are seasoned expert witnesses both with respect to direct claims and reinsurance claims. In addition, Westmont provides market conduct analysis and program management, and legislative/regulatory analysis and review on both state and federal issues. Westmont is an industry leader in serving both the world’s largest insurers as well as small, specialized regional insurers and program managers. Our knowledge and experience is your advantage.

You can also contact us at:

We hope to see you there!


1763 Marlton Pike East, #200
Cherry Hill, NJ 08003
Phone: 856-216-0220