Control
Insurer AI decision system without a written AIS Program / consumer notice
Insurers using AI systems for regulated insurance decisions must maintain a written AIS Program (governance, risk controls, lifecycle coverage, board accountability) and provide notice to impacted consumers that AI is in use.
Informational data, not legal advice. Summaries are TwinEthos's own words and rules have not been reviewed by a lawyer: check the official text before relying on any of it. A guard addresses an item; adding it is not a statement that your code meets any law.
Reach
The guard to add
Notify consumers when AI makes or supports their underwriting, rating, or claims decision, and list that model in the insurer's written AIS Program.
In the code path that calls a model for underwriting, rating, premium quoting, or claims decisions, send or render a consumer notice that AI systems are used (in the quote flow, claim acknowledgement, or decision letter) and record that it was delivered. The model is an entry in the insurer's written AIS Program, covering governance, risk-management controls, internal audit, lifecycle management, third-party systems, and an accountable leader, with an owner; keep the inventory entry or a pointer to it in the repository so each decision path is traceable to its program record.
Where it goes: 9 AI output handling, 14 user-facing text, 12 repository artifacts.
What reviewers look for: in each file that turns model output into an underwriting, rating, or claims result, a consumer AI-use notice (ai_use_notice, consumer_notice, send_ai_notice(, notify_consumer() that reaches the consumer; an AIS Program document and an inventory entry for the model with owner and third-party vendor noted.
Example (Python + OpenAI SDK), before:
resp = client.chat.completions.create(model=MODEL, messages=claim_msgs)
claim_decision = parse_decision(resp.choices[0].message.content)
claims.update(claim_id, status=claim_decision)After:
AI_USE_NOTICE = ('An AI system helped evaluate your claim. '
'You can ask us how it was used and request review by a claims adjuster.')
resp = client.chat.completions.create(model=MODEL, messages=claim_msgs)
claim_decision = parse_decision(resp.choices[0].message.content)
claims.update(claim_id, status=claim_decision, ais_program_ref='AIS-012')
send_ai_notice(claimant, text=AI_USE_NOTICE)Engineering guidance, not legal advice. Each provision below may add its own details (a cadence, a deadline, a required notice element): open it for those.
Every rule this guard addresses
Standard / soft law (1)
- United States (federal) (US)
- Insurers adopting the NAIC model guidance should maintain an AIS Program and AI-use notice NAIC Model Bulletin, AIS Program Guidelines 1.1-1.9