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West Virginia Issued Bulletin No. 24-06 RE: Artificial ‎Intelligence

On August 9, 2024, the West Virginia Office of the Insurance Commissioner issued Bulletin 24-06 on Artificial Intelligence Systems (“Bulletin”). The Bulletin is applicable to “all insurers authorized to do business in West...more

Michigan Issued Bulletin 2024-20-INS RE: Use of AIS in ‎Insurers

On August 7, 2024, Michigan issued Bulletin 2024-20-INS on the Use of Artificial Intelligence Systems By Insurers. The Bulletin is applicable to all Insurers, Nonprofit Health Services Plans, HMOs, and Dental Plan...more

Arkansas Issued Bulletin 13-2024 RE: Use of AIS in Insurance

On July 31, 2024, Arkansas issued Bulletin 13-2024 on the Use of Artificial Intelligence Systems in Insurance. The Bulletin is applicable to all companies licensed to do business in Arkansas and is based upon the NAIC Model...more

Virginia Issued Administrative Letter 2024-01 RE: Use of AIS‎

On Monday, July 22, 2024, the Virginia Bureau of Insurance (“Bureau”) issued Administrative Letter 2024-01 on the Use of Artificial Intelligence Systems which is applicable to all companies licensed to conduct the business of...more

Nebraska Adopts AI Guidance

On June 11, 2024, the Nebraska Insurance Department issued Guidance IGD-H1 on the Use of AI By Insurers. This brings the total to 13 jurisdictions that have adopted the NAIC Model Bulletin on the Use of AI Systems in...more

PHL Variable Insurance Company in ‎Rehabilitation At A Glance

On Friday, May 17, 2024, Connecticut Insurance Commissioner Mais filed a Petition for Rehabilitation and Appointment of the Commissioner as Rehabilitator of PHL Variable Insurance Company ("PHL"), a Connecticut domestic stock...more

DC Adopts Bulletin 24-IB-002-05/21 on the Use of Artificial Intelligence Systems in Insurance

On May 21, 2024, the DC Insurance Commissioner, Karima M. Woods, issued Bulletin 24-IB-002-05/21 on the Use of Artificial Intelligence Systems in Insurance to all Insurers licensed to do business in the District of Columbia....more

Washington Issues Technical Assistance Advisory 2024-02 Regarding the Use of AI in ‎Insurance

On April 22, 2024, the Washington Office of the Insurance Commissioner issued Technical Assistance Advisory 2024-02 regarding “The Use of Artificial Intelligence Systems in Insurance” (the “Advisory”). The Advisory applies to...more

Kentucky Issues Bulletin 2024-02 on the Use of AI in Insurance

On April 16, 2024, the Kentucky Department of Insurance issued Bulletin 2024-02 to all insurers licensed to do business in Kentucky regarding the Use of Artificial Intelligence Systems in the Business of Insurance effective...more

Maryland Issues Bulletin No. 24-11 on the Use of AI in Insurance

Commissioner Kathleen Birrane, Maryland Insurance Administration, on April 22, 2024 issued Bulletin No. 24-11, The Use of Artificial Intelligence Systems in Insurance (the “Bulletin”). The Bulletin applies to “all Insurers,...more

Illinois Appoints New Insurance Director

Effective April 15, 2024, Illinois will have a new Acting Insurance Director, Illinois State Senator Ann Gillespie....more

Pennsylvania Adopts NAIC Model Bulletin on the Use of Artificial Intelligence by Insurers

On Saturday, April 6, 2024, Pennsylvania adopted 54 Pa.B. 1910 based upon the NAIC Model Bulletin on the Use of Artificial Intelligence Systems by Insurers; Notice 2024-04....more

Colorado Division of Insurance Holds Second Health Insurance Stakeholder Meeting for ‎Implementing AI Requirements

On Tuesday, April 2, 2024, the Colorado Division of Insurance (“Division”) held its second Unfair Discrimination in Insurance Practices – Health Insurance Stakeholder meeting where the Division discussed efforts to develop...more

NAIC Model Bulletin on the Use of AI Systems by Insurers Adopted in Eight States

Nevada has adopted the NAIC Model Bulletin on the Use of AI Systems by Insurers along with seven other states, including Alaska, Connecticut, Illinois, New Hampshire, Nevada, Rhode Island and Vermont....more

NY DFS Jumps on the AI Bandwagon by ‎Issuing Proposed Guidance to ‎New York Licensed Insurers ‎Relating to Underwriting

On January 17, 2024, the New York Department of Financial Services (“NYDFS”) exposed for comment a proposed circular letter regarding “Use of Artificial Intelligence Systems and External Consumer Data and Information Sources...more

Artificial Intelligence Regulation in the ‎Insurance Industry – 2023 a Year in Review

2023 has been a very productive year for regulators advancing their efforts to understand new technologies and consider whether and how to regulate the rapidly developing technologies, including artificial intelligence,...more

Colorado Exposes Draft Life Insurance ‎AI Data Testing Regulations for Unfair ‎Discrimination

On September 27, 2023, the Colorado Division of Insurance (the “Division”) exposed a new proposed regulation entitled “Concerning Quantitative Testing of External Consumer Data and Information Sources, Algorithms, and...more

Colorado Insurance Division Adopts ‎Proposed Algorithm and Predictive Model Governance ‎‎Regulation

On September 21, 2023, the Colorado Insurance Division adopted Regulation 10-1-1 entitled “Governance and Risk Management Framework Requirements for Life Insurers’ Use of External Consumer Data and Information Sources,...more

Insurance Regulators ‎Continue to ‎Grapple With the Rapid Development ‎and ‎Use of Artificial ‎Intelligence

On August 13, 2023, insurance regulators and the insurance industry met in Seattle, Washington at the NAIC Summer Meeting and continued to address the challenges of monitoring and regulating the insurance industry’s use of...more

NAIC Exposes Draft Artificial ‎Intelligence Model Bulletin

On July 17, 2023, the NAIC released the Exposure Draft of the Model Bulletin on the Use of Algorithms, Predictive Models, and Artificial Intelligence Systems by Insurers. Written comments will be accepted by the NAIC through...more

Artificial Intelligence: The Expansion of ‎Growth Opportunities for Health Insurers and ‎Related ‎Regulatory Hurdles

The stories of artificial intelligence applications and ChatGPT are all over the news with daily reports of new uses and challenges. With the mind-boggling speed at which generative artificial intelligence is developing, it...more

Grappling With Increased Insurance ‎Regulatory Scrutiny of Pharmacy Benefit Managers

Insurance regulators and examiners (“Insurance Regulators”) are increasing their efforts to scrutinize pharmacy benefit managers (“PBMs”), including conducting examinations of their business operations and initiating...more

Illinois Establishes a New State-Based ‎Health Insurance Exchange Marketplace and New ‎Health ‎Insurance Rate Regulation

On June 27, 2023, Illinois enacted two new state insurance laws creating a new state-based health Insurance exchange marketplace (HB 579) and requiring health insurers to comply with rate regulation (HB 2296)....more

Protecting the Parties’ Rights Under ‎Qualified Financial Contracts and Netting Agreements ‎When an ‎Insurer Goes Into...

As the derivative exposure of U.S. insurers continues to increase and the industry increasingly engages in derivative transactions, including Qualified Financial Contracts (“QFCs”) and Netting Agreements (defined below), it...more

Take Aways From The NAIC Special Session On COVID-19 (Public Portion)

The National Association of Insurance Commissioners (“NAIC”) on Friday, March 20, 2020 held a Special Session on COVID-19. The session was broken into two parts: the first, open to the public call in the morning and second,...more

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