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The Revised Colorado AI Insurance Regulations: What Was Fixed, and What Still May Need Fixing
1 June 2023
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On May 26, 2023, the Colorado Division of Insurance (the “DOI”) released its Revised Draft Algorithm and Predictive Model Governance Regulation (the “Revised Regulation”), amending its initial draft regulation (the “Initial Regulation”), which was released on February 1, 2023. The Revised Regulation imposes requirements on Colorado-licensed life insurance companies that use external consumer data and information sources (“ECDIS”), as well as algorithms and predictive models (“AI models”) that use ECDIS, in insurance practices.
Many of the documentation obligations contained in the Initial Regulation were either removed or changed in the Revised Regulation.
The regulation calls for the creation of a cross-functional group. Determining which representatives from “key functional areas” should be in the group, how often the group should meet, what resources it needs, to whom it will report, how it will make decisions, and how its decisions will be implemented are all complicated considerations that will take time and discussion.
Data Strategy & Security
Samuel J. Allaman
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