Project Whitehall: New York Department of Financial Services Pilots Program for Insurtech Innovation
Legal Development 28 February 2020 28 February 2020
The New York Department of Financial Services has launched Project Whitehall, a pilot program intended to support insurtech innovators seeking guidance on regulatory questions.
The New York Department of Financial Services (NY DFS) has launched Project Whitehall, a pilot program intended to support insurtech innovators seeking guidance on regulatory questions from the NY DFS. The website for Project Whitehall contains a form completed by the inquirer, which is meant to lead to a meeting between the NY DFS and the insurtech innovators making the request. According to the NY DFS, such “meetings [will be] intended to be informational in nature and to help innovators navigate [the NY DFS’s] requirements through greater engagement with expert [NY] DFS staff in an informal setting.”
The form requires submission of relatively detailed information, such as a description of the inquirer’s business, insurtech innovation, and the expected service or product’s benefits to customers in New York, as well as the inquirer’s understanding of how New York insurance laws and regulations might apply to the proposed business and products. The form also invites the inquirer to submit supporting documents such as a business plan, pitch deck or white paper. However, the NY DFS warns that the information submitted may be subject to public disclosure under New York’s Freedom of Information Law and therefore innovators should not submit sensitive or confidential information.
Although this pilot program offers a good opportunity for insurtech innovators to obtain regulatory guidance on innovative ideas for the insurance marketplace in New York, it will be important that any insurtech innovators making such requests to the NY DFS do so after careful review and consideration. Project Whitehall is not an insurtech regulatory “sandbox” program such as offered by Kentucky and Vermont, which may grant a startup temporary relief from certain statutory and regulatory requirements under the states’ insurance laws to allow for faster testing of new insurance products and services. Instead, as the NY DFS itself notes, they are most interested in receiving queries from innovators who have already researched how the regulatory requirements may impact their business model and have “specific questions” for the NY DFS. Any inquiries must be carefully prepared and focused in nature because any guidance received from the NY DFS could potentially mean the difference between being able to launch the business or product in New York or not.