On January 17, 2024, the New York State Department of Financial Services (“NYDFS”) issued a proposed circular letter for comment regarding the “Use of Artificial Intelligence Systems and External Consumer Data and Information Sources in Insurance Underwriting and Pricing” (the “Circular Letter”). The Circular Letter details NYDFS’ expectations and guidelines for the use of artificial intelligence systems (“AIS”) and external consumer data and information sources (“ECDIS”) by “all insurers authorized to write insurance in New York State, licensed fraternal benefit societies, and the New York State Insurance Fund (collectively, “Insurers”).