No incident notification commitment to the insurer is stated
You have not committed to a time within which the insurer is told of a security incident. Section 500.17 gives the carrier seventy-two hours to notify its own regulator once it determines an incident has occurred, including one at a third-party service provider, and section 500.11(b)(3) has the carrier require notice from its vendors for exactly that reason. A reviewer therefore looks for a vendor commitment inside that window, and treats a longer one, or none, as a term to be negotiated before the contract can be signed.
To fix: Commit to notifying the insurer within seventy-two hours or less of discovering an incident that touches their data, write it into the contract and the incident response plan, and record the number here.