NYSID to send warning letters
The Department has indicated that they plan to issue warning letters on CL6 filings if they find 3 or more deficiencies. While these could include statutory and regulatory issues, the most likely errors to trigger these warning letters are things like failing to follow the requirements of Circular Letter 8 (1999) www.ins.state.ny.us/circltr/1999/cl99_08.htm, Circular Letter 6 (2004) www.ins.state.ny.us/cl04_06.htm, and similar procedural requirements. These warning letters will put companies on notice that failure to improve could lead to a 6 month suspension of CL6 filing privileges.
The Department indicated that they also intend to send notices asking for explanations of particular deficiencies and that company submissions may be held in abeyance while these are resolved. Examples of the type of errors that would lead to these actions include using the incorrect certification form and significant errors in the certification itself. It was reported that they are still receiving submissions that purport to be CL6 submissions, but include the old and obsolete CL27 certification.
