Prepare for evidence requests while keeping draft developments separate from applicable law.

The NAIC working group currently lists the version 6.0 consultation closing on 30 October, a discussion meeting on 2 November, and its Fall National Meeting session on 16 November 2026. These are scheduled milestones, not evidence that a final supplement has been adopted. (content.naic.org)

The adopted 2023 NAIC Model Bulletin addresses AI systems that make or support regulated decisions, including third-party systems, and describes risk-proportionate governance and testing. It is model guidance for state use, not a single federal rule. (content.naic.org)

Our proposed Evidence-to-Approval Control Audit should ask for:

1. An inventory: tool, supplier, use case, business owner and authorised users.
2. A traceable record: source evidence, output, model or rule version, reviewer intervention and final disposition.
3. Validation: representative testing, material-defect definitions, known limitations and regression results after changes.
4. Third-party controls: data handling, retention, subprocessors, training-use restrictions, audit access and exit arrangements.
5. Decision boundaries: who may draft, amend, approve, communicate and authorise payment.

These are proposed diligence questions, not a claim that every item is universally mandated. Wisconsin’s bulletin supplies a concrete state example of expectations covering third-party diligence, audit arrangements and regulatory cooperation. Have counsel map requirements to each jurisdiction and service scope. (oci.wi.gov)