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 Circular Letter). The Proposed Circular Letter supplements the DFS’s Insurance Circular Letter No. 1 (January 18, 2019) (the 2019 Circular Letter), which addressed the use of external consumer data and information sources in underwriting for life insurance and is representative of part of a trend of increased scrutiny by regulators and legislators on the role of artificial intelligence in the insurance industry.