You didn't at the time. The reason we got flagged was because we started talking to insurers about adding a policy at one point in anticipation of hiring.

What a racket?! So the insurers send their list of failed leads over to the regulators so they'll get fined?

Somewhat off-topic: do you know of any good resources to read about these sorts of requirements for NYC or the US more broadly?

Most sites gloss over these sorts of legal requirements.