AI Regulation in the Insurance Industry: Impacts of the New York Circular

The New York Department of Financial Services (NYDFS) issued Insurance Circular Letter No. 7, which provides guidance on the use of Artificial Intelligence (AI) and External Consumer Data and Information Sources (ECDIS) in insurance underwriting and pricing. The Circular has significant implications for the insurance industry, especially in the areas of data governance, algorithmic accountability, and consumer protection.

DLA Piper's Kathleen Birrane, Zev Eigen, and Mike O'Day discuss the key aspects of the circular, the challenges and opportunities it presents for insurers, and the best practices for compliance and risk management.

Feature video

What you need to know

Kathleen Birrane compares the New York Circular to the NAIC’s bulletin.



Kathleen Birrane identifies similarities in the NAIC’s bulletin and New York Circular.

What are the important differences between the New York Circular and the NAIC’s bulletin?

Kathleen Birrane points out a key risk factor with external data.



Understand how risk factors may cause tension.



Dr. Zev Eigen on context and room for interpretation in analyses.

The problem with a “hammer looking for a nail” approach.



Dr. Zev Eigen raises the issues with variables

Additional resources