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The complex and evolving AI regulatory landscape for insurers is again on the move. The Colorado Division of Insurance (the Division) has commenced the formal rulemaking process to amend and expand the reach of current...more
Since the start of 2025, the following states have added to the roadwork on artificial intelligence regulation in insurance by implementing the NAIC’s model bulletin on the use of AI systems by insurers...more
During the NAIC Spring National Meeting, the Big Data and Artificial Intelligence (H) Working Group reviewed its blueprint to build an overarching regulatory edifice to oversee insurers’ use of artificial intelligence...more
The Mitchell Williams Insurance Regulatory team of attorneys recently attended the National Association of Insurance Commissioners (NAIC) Spring 2025 National Meeting which was held in Indianapolis, Indiana. We have prepared...more
The Maynard Nexsen Insurance Regulatory team of attorneys attended the National Association of Insurance Commissioners (NAIC) Spring National Meeting held on March 23-26 in Indianapolis, Indiana. As expected, regulators,...more
As of March 2025, 24 states have adopted the National Association of Insurance Commissioners (NAIC) Model Bulletin on the Use of Artificial Intelligence (AI) Systems by insurers with little to no material changes. As we...more
On February 11, New Jersey Banking and Insurance Commissioner Zimmerman issued Bulletin 25-03 regarding the use of artificial intelligence systems (AIS) in insurance, applicable to all insurers authorized or admitted in New...more
On February 5, Delaware joined 21 jurisdictions who adopted guidance similar to the NAIC Model Bulletin on the Use of Artificial Intelligence (AI) Systems by Insurers in 2024, and four additional jurisdictions have otherwise...more
Regulators are growing concerned about the delegation of various insurance company functions, prompting a closer examination of third-party vendors. Several groups within the National Association of Insurance Commissioners...more
Many of the skirmishes fought under the Gold Dome each year are turf wars, sometimes literally. A perennial favorite is the dispute over Georgia’s northern border, which Representative Martin Momtahan (R-Dallas) is seeking to...more
Since the 2023 adoption by the National Association of Insurance Commissioners of its model bulletin on the use of AI systems by insurers, states have been adopting the model bulletin or draft requirements of their own. Below...more
2024 has seen a significant amount of activity by state insurance regulators and the National Association of Insurance Commissioners (the “NAIC”) including the adoption of major revisions to the regimes governing investments...more
The Situation: The global market for artificial intelligence ("AI") technologies is projected to surpass $1 trillion by 2030....more
State regulators are taking action on the use of artificial intelligence in insurance. To date, nearly a dozen states have adopted some form of the National Association of Insurance Commissioners (NAIC) Model Bulletin on the...more
A "time cut" is a ruling within cycling to ensure that riders keep pace. Similarly, regulators have placed time cuts, or deadlines, for insurers to certify compliance with cybersecurity regulations. Some of the time cuts are...more
After strapping on their skis and riding up the lifts, the NAIC groups reported to their events. The results of the events of note for life insurers are as follows...more
States have been off to the races to place in the artificial intelligence insurance regulatory Grand Prix. The NAIC adopted the Model Bulletin on the Use of AI Systems by Insurers, which some states have drafted on to adopt...more
On January 17, 2024, the New York State Department of Financial Services (DFS) issued for public comment a proposed circular letter on the use of AIS and external data sources by New York-authorized insurers (the Proposed...more
As the implementation and integration of artificial intelligence and machine learning tools (AI) continue to affect nearly every industry, concerns over AI’s potentially discriminatory effects in the use of these tools...more
On January 17, 2024, the New York State Department of Financial Services (NY DFS) released for public comment a proposed circular letter (Proposed Letter) to regulate the use of artificial intelligence systems (AIS) and...more
On January 17, 2024, the New York State Department of Financial Services (“NYSDFS”) released a proposed circular letter addressing the use of external consumer data and information sources (“ECDIS”) and artificial...more
The New York State Department of Financial Services (“DFS”) has entered its voice regarding the use of artificial intelligence (“AI”) by insurers by issuing for public comment a proposed circular letter addressing the use of...more
On December 4, the National Association of Insurance Commissioners unanimously adopted a model bulletin on the use of artificial intelligence in insurance. The model bulletin is intended for use by state insurance regulators...more
On November 14, 2023, the Colorado Division of Insurance’s AI insurance regulations went into effect. Colorado is now the first state in the nation to adopt regulations specifically aimed at insurance algorithms....more
Regulators Hit Jackpot: Off-Channel Communications - Several years before announcing the first “off-channel” communications enforcement action, the SEC and FINRA cautioned broker-dealers and investment advisers about...more