On February 4, 2021, the New York State Department of Financial Services (the “DFS”) issued Insurance Circular Letter No. 2 (2021), which includes a “Cyber Insurance Risk Framework” (collectively, the “Framework”), to outline what the DFS describes as best practices for managing cyber insurance risk. Among other things, the Framework urges all property and casualty insurers licensed in New York to establish a cyber risk insurance strategy directed and approved at the insurers’ highest levels and identifies principles to consider when developing an effective and sustainable program in response to the ever-heightening risks posed by cyber events.