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PIA Comments on Draft NAIC Cybersecurity Model

PIA National has filed extensive comments on the National Association of Insurance Commissioners (NAIC) Cybersecurity Task Force’s August 17, 2016 Draft of the Insurance Data Security Model Law (referred to as “August 17 draft”)...
September 19, 2016

PIA National has filed extensive comments on the  National Association of Insurance Commissioners (NAIC) Cybersecurity Task Force’s August 17, 2016 Draft of the Insurance Data Security Model Law (referred to as “August 17 draft”).

PIA recognizes and appreciates that some of the concerns raised earlier this year have been addressed in the August 17 draft. However, the August 17 draft still leaves us with a sizeable number of serious reservations.


“The pursuit of transforming this August 17 draft into a standard state law would be a futile attempt to chase uniformity in an area already dominated by functional state laws,” PIA notes. “As written, the August 17 draft is not an improvement over the existing patchwork of state laws, and, as such, without substantial revision, we are unable to support the August 17 model within the NAIC process or at the state legislative level.” Read PIA’s comments here.

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