New York City Council 
Committee on Consumer and Worker Protection 

Thank you, Chair Epstein and members of the committee, for the opportunity to testify on Int. 685 which would establish a city Office of Insurance Accountability (OIA) within the Department of Consumer and Worker Protection. The Partnership for New York City mobilizes private sector resources and expertise to advance New York City’s standing as a global center of economic opportunity, upward mobility, and innovation. We are a nonprofit organization whose members are preeminent business leaders and companies that support nearly one million jobs in New York City and deliver approximately $263 billion in economic output. 

The Partnership opposes Int. 685. While we appreciate the Council’s interest in helping consumers navigate the complexities of insurance, we believe that Int. 685 would create unnecessary duplication, additional administrative burdens, and confusion without providing meaningful new protections or tools for consumers. 

The New York State Department of Financial Services (DFS) has comprehensive authority over the insurance industry. The proposed OIA created by Int. 685 would duplicate some of the functions of DFS but would have no authority to regulate the insurance industry or require insurers to take corrective action. Given DFS’s broad authority and existing expertise, it is unclear what additional value a city office without regulatory power would provide. 

Although the proposed OIA cannot explicitly regulate insurers, the office’s mandate to study insurance costs, track legal actions, and issue reports strongly suggests that it would need to request data and information directly from insurance companies. This would create duplicative information requests overlapping with existing DFS reporting requirements and additional compliance and administrative costs with no clear benefit to consumers or the market.

Int. 685 would establish a new city-level avenue for consumer complaints about insurers. However, the proposed OIA would not have the authority to compel insurers to resolve disputes. As a result, complaints would likely need to be referred to DFS or other entities for action. This would force insurers to respond to multiple government agencies regarding the same issue. Instead of resolving issues more quickly, this fragmented approach risks confusing consumers, slowing outcomes, and increasing inefficiencies. Consumers are best served by a clear, centralized complaint process which is already provided by DFS. 

Finally, Int. 685 would authorize the OIA to make policy recommendations to stabilize or lower insurance costs, yet it provides no mechanism to implement those recommendations. Insurance costs are driven by complex factors, including underwriting standards, reinsurance markets, litigation exposure, and state law mandates. A city office without regulatory authority cannot meaningfully influence these drivers, raising questions about the practical purpose of such recommendations. 

Creating a new city office requires additional resources such as staff. Given the city’s current budget challenges, it does not make sense to require additional city resources for an office that would not add any new benefits for consumers. 

The Partnership urges the Council not to move forward with Int. 685. 

Thank you.