EX-99.77B ACCT LTTR

INDEPENDENT AUDITORS' REPORT

The Board of Directors and Shareholders,
MuniHoldings New York Insured Fund, Inc.:

In planning and performing our audit of the financial
statements of MuniHoldings New York Insured Fund, Inc.
(the "Fund") for the year ended August 31, 2002 (on which
we have issued our report dated October 9, 2002), we
considered its internal control, including control activities
for safeguarding securities, in order to determine our
auditing procedures for the purpose of expressing our
opinion on the financial statements and to comply with the
requirements of Form N-SAR, and not to provide assurance
on the Fund's internal control.

The management of the Fund is responsible for establishing
and maintaining internal control.  In fulfilling this
responsibility, estimates and judgments by management are
required to assess the expected benefits and related costs of
controls.  Generally, controls that are relevant to an audit
pertain to the entity's objective of preparing financial
statements for external purposes that are fairly presented in
conformity with accounting principles generally accepted
in the United States of America.  Those controls include the
safeguarding of assets against unauthorized acquisition,
use, or disposition.

Because of inherent limitations in any internal control,
misstatements due to error or fraud may occur and not be
detected.  Also, projections of any evaluation of internal
control to future periods are subject to the risk that the
internal control may become inadequate because of changes
in conditions, or that the degree of compliance with policies
or procedures may deteriorate.

Our consideration of the Fund's internal control would not
necessarily disclose all matters in the internal control that
might be material weaknesses under standards established
by the American Institute of Certified Public Accountants.
A material weakness is a condition in which the design or
operation of one or more of the internal control components
does not reduce to a relatively low level the risk that
misstatements caused by error or fraud in amounts that
would be material in relation to the financial statements
being audited may occur and not be detected within a
timely period by employees in the normal course of
performing their assigned functions.  However, we noted
no matters involving the Fund's internal control and its
operation, including controls for safeguarding securities,
that we consider to be material weaknesses as defined
above as of August 31, 2002.

This report is intended solely for the information and use of
management, the Board of Directors and Shareholders of
the Fund, and the Securities and Exchange Commission
and is not intended to be and should not be used by anyone
other than these specified parties.

/s/ Deloitte & Touche LLP

New York, New York
October 9, 2002

EX-99.77O RULE 10F-3

MUNIHOLDINGS NEW YORK INSURED FUND, INC.

FILE # 811-8217

ATTACHMENT 77O

TRADE DATE	DESCRIPTION OF SECURITY	AMOUNT PURCHASED	ISSUE SIZE	MEMBER OF UNDERWRITING SYNDICATE FROM WHOM FUND PURCHASED
03/06/02	Triboro Bridge & Tunnel 5.5% 01/01/32	$10,600,000	$268,300,000	Paine Webber
03/13/02	New York City GO 5.75% 03/15/27	$27,000,000	$500,000,000	Goldman Sach
05/03/02	NYS Environment Wtr 5.5% 6/15/14	$7,200,000	$518,940,000	Bear Stearns
05/09/02	MTA 5.75% 11/15/32	$50,000,000	$2,894,185,000	Bear Stearns
06/05/02	MTA 5.75% 7/1/31	$30,000,000	$1,715,755,000	Lehman Bros
06/14/02	NYC TFA 5.5% 11/1/26	$2,500,000	$435,805,000	Lehman Bros
06/21/02	NYS Thruway Auth 5.0% 4/1/19	$6,500,000	$435,805,000	Paine Webber
06/21/02	NYS Thruway Auth 5.0% 4/1/20	$8,500,000	$435,805,000	Paine Webber
07/12/02	NYC Hlth & Hosp 5.375% 2/15/16	$705,000	$192,750,000	Paine Webber
08/15/02	Tobacco Settlement Fin Corp 6% 06/01/37	$8,640,000	$1,801,455,000	Salomon

EX-99.77P EXMPT INFO

MuniHoldings New York Insured Fund, Inc.
File Number:  811-8217
CIK Number:  1038186
For the Period Ending:  08/31/2002
Pursuant to Exemptive Order No. IC-15520 the following schedule enumerates the transactions with Merrill Lynch, Pierce, Fenner & Smith Incorporated, for the year ended August 31, 2002.
Sales (In Thousands)
Transaction	Face	Security		Due
Date	Amount	Description	Rate	Date
09/07/2001	$300	New York City, New York	2.25%	08/01/2020

EX-99.77Q3 CERT

Item 77Q3(a)(i)

The registrant’s certifying officers have reasonably designed such disclosure controls and procedures to ensure material information relating to the registrant is made known to us by others particularly during the period in which this report is being prepared.  The registrant’s certifying officers have determined that the registrant’s disclosure controls and procedures are effective based on our evaluation of these controls and procedures as of a date within 90 days prior to the filing date of this report..

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Item 77Q3(a)(ii)

There were no significant changes in the registrant’s internal controls or in other factors that could significantly affect these controls subsequent to the date of their evaluation, including any corrective actions with regard to significant deficiencies and material weaknesses.

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EX-99.77Q3 CERT

CERTIFICATION PURSUANT TO SECTION 302

OF THE SARBANES-OXLEY ACT OF 2002

I, Donald C. Burke, Chief Financial Officer of MuniHoldings New York Insured Fund, Inc., certify that:

1.

I have reviewed this report on Form N-SAR of MuniHoldings New York Insured Fund, Inc.;

2.

Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by this report;

3.

Based on my knowledge, the financial information included in this report, and the financial statements on which the financial information is based, fairly present in all material respects the financial condition, results of operations, changes in net assets, and cash flows (if the financial statements are required to include a statement of cash flows) of the registrant as of, and for, the periods presented in this report;

4.

The registrant’s other certifying officers and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in rule 30a-2(c) under the Investment Company Act) for the registrant and have:

a)

designed such disclosure controls and procedures to ensure that material information related to the registrant, including its consolidated subsidiaries, is made known to us by others within those entities, particularly during the period in which this report is being prepared;

b)

evaluated the effectiveness of the registrant’s disclosure controls and procedures as of a date within 90 days prior to the filing date of this report (the “Evaluation Date”); and

c)

presented in this report our conclusions about the effectiveness of the disclosure controls and procedures based on our evaluation as of the Evaluation Date;

1.

The registrant’s other certifying officers and I have disclosed, based on our most recent evaluation, to the registrant’s auditors and the audit committee of the registrant’s board of directors (or persons performing the equivalent functions):

a)

all significant deficiencies in the design or operation of internal controls which could adversely affect the registrant’s ability to record, process, summarize, and report financial data and have identified for the registrant’s auditors any material weaknesses in internal controls; and

b)

any fraud, whether or not material, that involves management or other employees who have a significant role in the registrant’s internal controls; and

1.

The registrant’s other certifying officers and I have indicated in this report whether or not there were significant changes in internal controls or in other factors that could significantly affect internal controls subsequent to the date of our most recent evaluation, including any corrective actions with regard to significant deficiencies and material weaknesses.

Date: October 28, 2002

_/s/ Donald C. Burke________

(Donald C. Burke

Chief Financial Officer of

MuniHoldings New York Insured Fund, Inc.)

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EX-99.77Q3 CERT

CERTIFICATION PURSUANT TO SECTION 302

OF THE SARBANES-OXLEY ACT OF 2002

I, Terry K. Glenn, President of MuniHoldings New York Insured Fund, Inc., certify that:

1.

I have reviewed this report on Form N-SAR of MuniHoldings New York Insured Fund, Inc.;

2.

Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by this report;

3.

Based on my knowledge, the financial information included in this report, and the financial statements on which the financial information is based, fairly present in all material respects the financial condition, results of operations, changes in net assets, and cash flows (if the financial statements are required to include a statement of cash flows) of the registrant as of, and for, the periods presented in this report;

4.

The registrant’s other certifying officers and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in rule 30a-2(c) under the Investment Company Act) for the registrant and have:

a)

designed such disclosure controls and procedures to ensure that material information related to the registrant, including its consolidated subsidiaries, is made known to us by others within those entities, particularly during the period in which this report is being prepared;

b)

evaluated the effectiveness of the registrant’s disclosure controls and procedures as of a date within 90 days prior to the filing date of this report (the “Evaluation Date”); and

c)

presented in this report our conclusions about the effectiveness of the disclosure controls and procedures based on our evaluation as of the Evaluation Date;

5.  The registrant’s other certifying officers and I have disclosed, based on our most recent evaluation, to the registrant’s auditors and the audit committee of the registrant’s board of directors (or persons performing the equivalent functions):

a)

all significant deficiencies in the design or operation of internal controls which could adversely affect the registrant’s ability to record, process, summarize, and report financial data and have identified for the registrant’s auditors any material weaknesses in internal controls; and

b)

any fraud, whether or not material, that involves management or other employees who have a significant role in the registrant’s internal controls; and

6.  The registrant’s other certifying officers and I have indicated in this report whether or not there were significant changes in internal controls or in other factors that could significantly affect internal controls subsequent to the date of our most recent evaluation, including any corrective actions with regard to significant deficiencies and material weaknesses.

Date: October 28, 2002

_/s/ Terry K. Glenn________

(Terry K. Glenn

President of MuniHoldings

New York Insured Fund, Inc.)

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