The National Association of Insurance Commissioners’ (NAIC) Third-Party Data and Models (H) Working Group issued a preview of its breakout single: a proposed risk-based regulatory framework for third-party data and model vendors. While stressing that insurers are still responsible for carrying the accountability tune, the draft
framework’s melody focuses on ensuring regulatory oversight of such vendors, particularly with respect to insurance functions with direct consumer impact.
The proposal, however, is likely to strike some sour notes, including:
- Vendor registration
- Annual attestations
- Regulatory access requirements
- Material change notifications
- State-specific, discretionary model filings and reviews
The group is accepting comments until February 6, and there is much unsung. What harmonies will be struck, what tempo the process will take, and how much of this proposal will remain on the studio floor remain to be seen.
