Does the date as of which a covered policy is renewed need to be determined by the actual date of the policy's renewal?

(d) As with plaintiff's reading, there is modest support in New York case law for defendant's reading. Under an analogous and almost identically worded provision in Section 3426 of the Insurance Law (governing commercial lines insurance), one New York court has treated "the date as of which a covered policy is renewed" as the effective date of the renewal rather than the actual date of the renewal's execution. See Pallotta v. Physicians' Reciprocal Insurers, 520 N.Y.S.2d 105, 106-07, 137 Misc. 2d 223, 224-27 (Sup. Ct., Nassau Cty. 1987). However, the precise timing of the required policy period was not at issue in that case, and the court gave no consideration to alternative possibilities. See id.