Life Agents to Regulators: Slow Down So We Have a Chance to Chat
NAIFA-NYS Advocating DFS to Suspend Reg 187 Effort Until All Interested Parties Can Roundtable Issues and Ideas

Albany, New York, June 19, 2018 — ‎The National Association of Insurance and Financial Advisors-New York State on Friday announced that it has requested the Department of Financial Services to stand down in its pursuit of amendments to Regulation 187, which would apply onerous new standards to all life insurance products.  The request came in the association’s public comment letter on the regulations, which were due on Friday.

“It is not necessarily that we are opposed to the principle behind the regulation, or the drive for greater consumer protections,” said Joseph Tavernite, NAIFA-NYS president, “but we think that the DFS approach may actually hurt consumers in the long run by cutting off access to important and affordable life insurance products.”

NAIFA-NYS submitted an eight-page comment letter in response to the department’s second draft of the regulation.  In it, the association highlighted a number of glaring concerns, including

  • including all forms of life insurance, including term insurance, in the regulation, imposing requirements more suitable for annuities and other complex insurance products;
  • exempting direct sales, such as mass-marketing, internet and phone sales, from the new regulations but still requiring agent-initiated sales to comply;
  • significantly increasing the paperwork that would have to be executed by prospective clients

NAIFA-NYS is suggesting a roundtable discussion with the DFS to better understand the department’s motivations for the regulatory changes, and to help the regulators understand the impact that the regulations might have on the advisor-client relationship and on the availability of certain products in the market. The association is also recommending that the New York regulator work more in concern with those from the National Association of Insurance Commissioners and federal regulators to devise a single, uniform standard governing life insurance product sales.

“The DFS just met in a roundtable with bail bondsmen to better understand their issues, and impart to them the agency’s regulatory concerns,” Tavernite continued. “This is the process the DFS could and perhaps should have taken before embarking on the changes to Regulation 187.  While we appreciate them meeting with us on the draft changes, that is a bit like meeting after the horse is out of the barn.  A discussion could lead to a more informed regulatory change.

NAIFA-NYS and its local affiliates represent the interests of thousands of life insurance agents and their associates throughout New York State.  Our members are continuing a 98-year tradition of upholding the highest ethics of their profession and take pride in assisting their clients in making important financial decisions on issues ranging from asset management, growth of net worth, employee benefits, retirement and elder planning, life, health, long-term care and disability insurance planning, college funding, and business, succession and legacy planning. More information is available at

For more information, please contact Gregory Serio, NAIFA-NYS Executive Director, or Candace Thorson, Deputy Executive Director, at 518-915-1661 or at


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