News & Analysis as of

NYDFS Artificial Intelligence Insurance Regulations

Eversheds Sutherland (US) LLP

Recent Executive Order on disparate impact: what it means for insurer’s use of AI

On April 23, 2025, President Donald Trump issued an Executive Order titled “Restoring Equality of Opportunity and Meritocracy” (order). The order declares disparate impact theory to be “wholly inconsistent with the...more

Latham & Watkins LLP

New York Regulator Issues Proposed AI Guidance for Insurers

Latham & Watkins LLP on

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

Epstein Becker & Green

Insurers in the Crosshairs: New York Targets Consumer Data and AI-Infused Insurance Underwriting and Pricing

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

Eversheds Sutherland (US) LLP

New York Department of Financial Services proposes a circular letter on the use of artificial intelligence to underwrite insurance

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

Mayer Brown

New York State Department of Financial Services Issues Proposed Artificial Intelligence Circular Letter

Mayer Brown on

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

Patterson Belknap Webb & Tyler LLP

New York’s Department of Financial Services Seeks Comment on the Use of Artificial Intelligence in Insurance Underwriting and...

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

Carlton Fields

Expect Focus - Volume III, September 2023

Carlton Fields on

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

McDermott Will & Emery

Insurance Regulators Continue Big Data Scrutiny

We previously reported on regulators’ increased attention to the use of big data systems, including external consumer data and information sources, algorithms and predictive models. Recent announcements in Colorado, Louisiana...more

Kramer Levin Naftalis & Frankel LLP

Acquiring a Life Insurer — Things You Need to Know Now

With M&A activity for life insurers or blocks of in-force business poised for a possible spike, acquirers of life businesses should consider factors that are peculiar to, or disproportionately affect, the life and annuity...more

Kramer Levin Naftalis & Frankel LLP

NY Regulatory Guidance on AI Illustrates Compliance Challenges

The New York Department of Financial Services’ (DFS) January 2019 insurance circular letter, which advised New York-licensed life insurance carriers on the use of external consumer data and information sources in...more

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