On January 17, 2024, The New York Department of Financial Services (“DFS”) issued a proposed insurance circular letter regarding insurers’ use of external consumer data and information sources (“ECDIS”) and artificial intelligence systems (“AIS”) in underwriting and pricing. In recognizing that the use of ECDIS and AIS in underwriting and pricing could be beneficial to insurers and the public by expediting and increasing the accuracy of underwriting and pricing, the DFS also recognized risks associated with such practices. The DFS noted:
