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New York Emergency Regulation 200 Creates Search Requirements for Unclaimed Life Insurance Benefits

Matthew B. Criscuolo
John David Dickenson
Edwards Wildman Palmer LLP - West Palm Beach Office

Patrick J. Gennardo
Edwards Wildman Palmer LLP - New York Office

A. Kenneth Levine
Edwards Wildman Palmer LLP - West Palm Beach Office

May 24, 2012

Previously published on May 2012

In a May 14, 2012, press release, New York Governor Andrew Cuomo and Financial Services Superintendent Benjamin Lawsky, announced the issuance of Emergency Regulation 200, which creates search requirements for unclaimed life insurance benefits. Release of the Regulation came despite collaboration of the New York Department of Financial Services (“Department”) with the Life Insurance Council of New York in an effort to craft legislation (AB 9845 and SB 6943) to address the same issues. The Regulation will be effective June 14, 2012, and may be re-issued by the Department on an emergency basis without going through the formal regulation process.

Among other things, the Regulation requires that life insurers cross-check policies at least every three months with recent deaths using the Social Security Death Master File (“DMF”) or another database acceptable to the Department. Additionally, when a policy is sold, the insurer must request detailed beneficiary information, such as social security number and address, to facilitate locating and paying beneficiaries upon the insured’s death. For holding companies, multiple policies on the same person must be searched in the files of all the holding company’s insurers. Insurers must also cross-check policies with consumer requests received through the State’s new free on-line service, Lost Policy Finder, in an effort to help consumers locate life insurance policies that have been lost or misplaced.

Every year, life insurers must also submit to the Office of the State Comptroller the number of policies for which a death occurred but for which the insurers were unable to find a beneficiary.


The views expressed in this document are solely the views of the author and not Martindale-Hubbell. This document is intended for informational purposes only and is not legal advice or a substitute for consultation with a licensed legal professional in a particular case or circumstance.

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