Framework overlap

Does API 1164 cover NAIC Insurance Data Security Model Law (MDL-668)?

You hold API 1164 and have been told to do NAIC Insurance Data Security Model Law (MDL-668). Here is how much overlaps, control by control.

50% of NAIC Insurance Data Security Model Law (MDL-668) you already have

API 1164 already covers about 50% of NAIC Insurance Data Security Model Law (MDL-668), leaving 4 of 8 controls as genuinely new work.

Already covered 3 Likely covered 1 New work 4

What is genuinely new work

Nothing in API 1164 reaches these. This is the list to scope.

NAIC-3
Risk Assessment and Risk Management - Section 4(B) and 4(C)
NAIC-4
Board and Senior Management Oversight - Section 4(F)
NAIC-7
Employee Training, Awareness, and Personnel Security - Section 4(D)(7) and 4(E)
NAIC-8
NY DFS 23 NYCRR 500 Alignment and State Adoption Variances
Show the 4 you already have
NAIC-1
NAIC Model Law Adoption, Scope, and Licensee Definitions
NAIC-2
Information Security Program (ISP) - Section 4
NAIC-5
Third Party Service Provider Oversight - Section 4(F)(3) and Section 5
NAIC-6
Cybersecurity Event Investigation and Notification - Sections 6 and 7

How this is calculated

Already covered means a mapping runs from a control in API 1164 to that control. Likely covered means no direct mapping exists but both frameworks map to the same control in a third standard. New work means neither. We keep those separate rather than adding them into one friendlier number, because blending them would present a two-hop inference as a verified fact.

Coverage is not symmetric. Run it the other way and you will get a different number; both are correct.

From 332,959 cross-framework control mappings across 723 frameworks, 531 of them verified against their source documents. It does not tell you that you are compliant: a mapped control means the two standards ask for the same thing, not that you have done it.

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