IRI PROPOSES CHANGES TO NAIC ARTIFICIAL INTELLIGENCE MODEL BULLETIN

WASHINGTON, D.C. – A proposed model National Association of Insurance Commissioners bulletin on insurers’ use of algorithms, predictive models, and artificial intelligence (AI) should consider modifications, according to the Insured Retirement Institute (IRI).

In comments submitted to the NAIC Innovation, Cybersecurity and Technology (H) Committee, IRI noted that it shares the NAIC’s goal of ensuring that decisions impacting consumers that are made or supported by advanced analytical and computational technologies, including AI systems, comply with all existing applicable insurance laws and regulations.

However, IRI said its members have concerns around the expectations for third-party AI systems and contracts with such third parties.

“Third-party vendors may be unwilling to provide proprietary information regarding their data or models directly to insurance companies, and we believe recognition of this issue within the Bulletin is important,” wrote Sarah Wood, Director of State Policy and Regulatory Affairs.

Wood also offered input regarding the different types of AI technologies to ensure that the Bulletin appropriately considers the risks of these different types.

“We believe that there is a difference between predictive models that are trained on defined, labeled data (supervised by humans) and AI technologies that cannot be fully supervised (i.e., ChatGPT) and may or may not lead to a specific outcome,” Wood wrote. “It would be appropriate to differentiate between these different models and create a standard that is separate for each modeling type. We’d be happy to collaborate further with the Committee on how to address this issue.”

# # #

Contact: Dan Zielinski