A Cause of Action for Negligent Issuance of Life Insurance Policies?

Is there a cause of action in New York for the negligent issuance of an insurance policy?  This novel issue was raised in Katchalova v. Perchikov.  The Appellate Division, Second Department held that New York does not recognize such a cause of action.  The tragic facts involve decedent applying, with the help of Defendant Perchikov, for several life insurance polices.  During the application processes, the decedent misrepresented her income, her occupation, and her relationship with Perchikov.  After procuring one million dollar life insurance policies from the defendants Union Central Life Insurance Company, John Hancock, and Metropolitan Life Insurance Company, Perchikov allegedly murdered the decedent to obtain the proceeds of the life insurance policies.  The decedent's personal representative and administratrix commenced this action to recover damages for pain and suffering and wrongful death.