Effective March 1 all covered entities will be required to conduct due diligence on their third party service providers. Per the NY DFS, due diligence of Third Party Service Providers (TPSPs) is a two way street in the case of agents and brokers and carriers. The Big I New York board of directors' position is to take a reasonable approach to conducting due diligence that minimizes the burden on both agents and carriers.
Over the past few weeks, Big I NY leadership and staff have met with or had conference calls with over twenty carriers to share our board's position and to ask carriers to consider a simplified approach to compliance with the TPSP requirements of section 500.11 of the regulation. We also presented a carrier specific webinar on this subject on February 13, with 66 company reps in attendance. Should a carrier choose to use a questionnaire as part of their third party risk assessment, we have asked that they consider using a simplified approach or accepting an attestation from their carrier partners. We shared a simple questionnaire agents and carriers can use. If a carrier uses a contract or amends contract provisions as part of their due diligence process, we strongly suggest that they make any requirements mutual.
We have had excellent conversations with and feedback from the carriers and many are considering our suggested approach. Our goal is to support our members and the carriers they do business with and to ease confusion and frustration by providing resources and education on this important area.