On April 19, 2022, the New York State Department of Financial Services (DFS) issued Insurance Circular Letter No. 5 (2022) (Circular Letter) to all New York domiciled insurers and “other interested parties.” The Circular Letter provides a summary of existing New York Insurance Law (NYIL) requirements governing determinations of “control.” Under NYIL, similar to the insurance laws of other states, no person may directly or indirectly acquire “control” of a domestic insurer unless the Superintendent of the DFS provides its prior approval. While the Circular Letter does not change any existing laws or regulations, it provides guidance on how the DFS could broadly interpret existing laws and regulations governing control determinations, and sets forth the DFS’ expectations in regard to transactions that raise potential control issues.