New York Laws
Article 64 - Title Insurance Corporations
6407 - Restrictions on Dividends.

(b) No such corporation shall declare or pay any cash or property
dividend to shareholders which, together with all such dividends
declared or paid by it during the next preceding twelve months, exceeds
ten percent of its then outstanding capital shares unless, after
deducting such dividends, it has a surplus to policyholders at least
equal to fifty percent of its reinsurance reserve or a surplus at least
equal to fifty percent of the minimum capital required of such insurer
to transact the business of title insurance, whichever shall be greater.
For the purpose of this section, "surplus" means the amount of the
insurer's admitted assets in excess of (i) all of its liabilities,
including its reinsurance reserve, and (ii) its outstanding capital
shares.
(c) No such corporation shall declare or distribute any stock dividend
which shall reduce surplus to an amount less than fifty percent of its
then outstanding capital shares.