crosspractice-letter-NY-Proposed-Circular.pdf 1 March 14, 2024 New York State Department of Financial Services Via email: innovation@dfs.ny.gov Re: Proposed Circular on the use of AIS and ECDIS in Insurance Underwriting and Pricing To Whom it May Concern, On behalf of the Health, Life and Casualty practice councils (“the councils”) of the American Academy of Actuaries,1 we appreciate the opportuni. [...] The Department might consider including or referring to the definition of “rational explanation” in the NAIC’s Regulatory Review of Predictive Models white paper as another means to describe the “intuitive, logical relationship” in section 18 within a qualitative assessment. [...] We recommend that the Department specifically define the terms “unfair discrimination” and “unlawful discrimination” beyond the references in section 12, to help insurers differentiate between the terms to ensure appropriate and consistent compliance. [...] With respect to medical and personal information in section 35, the Department might consider following a process similar to the Fair Credit Reporting Act (FCRA), where the insurer informs the applicant how they can contact the third party to remedy their incorrect data. [...] Section 46 refers to random holdouts; we suggest asking companies to include the rationale as to why an applicant was moved to the traditional underwriting process to the disclosure.
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