The American Bankers Association joined a number of insurance trade associations in a comment letter to the National Association of Insurance Commissioners today providing feedback on the NAIC’s recently proposed insurance data security pre- and post-breach checklists. Specifically, the groups took issue with adding the checklists — which are based on an insurance data security model law that has not been enacted in most states — to the widely used Market Regulation Handbook.
Should the NAIC move forward with these additions, the associations urged it to qualify that the checklists should only be used in states that have enacted the model law. In addition, they called on the NAIC to consider recent revisions made to the IT section of the Financial Examiners Handbook and avoid duplication wherever possible.
