NAIC AI Governance Assessment for Insurance on AWS

The most specific AI regulatory scrutiny in US regulated industries is now on insurance.

The NAIC Model Bulletin on the Use of Artificial Intelligence Systems by Insurers (adopted December 2023) has been issued or adapted by roughly two dozen state insurance departments as of April 2026. Colorado SB 24-205 imposes algorithmic discrimination testing on high-risk AI systems. Colorado Division of Insurance Regulation 10-1-1 targets life insurance underwriting (first compliance reports due July 1, 2026). Texas TRAIGA (HB 149) includes insurance-specific governance triggers. New York DFS Insurance Circular Letter No. 7 (2024) sets expectations for external consumer data and AI underwriting. NAIC's AI Systems Evaluation Tool is in multi-state pilot (Jan–Sep 2026, across 12 states). Chief Actuaries, CCOs, CROs, and Chief Underwriting Officers need defensible, examiner-ready evidence that their pricing, underwriting, claims triage, fraud detection, and marketing AI systems meet these overlapping standards.

Kriv AI delivers a structured 3-week virtual assessment mapping your AI/ML inventory — including SageMaker, Bedrock, third-party scoring, and generative AI tools — to the NAIC Model Bulletin's four pillars.

3-week schedule:

Week 1 — Discovery + scoping. AI system inventory across all insurance functions (underwriting, claims adjudication, pricing/rating, SIU fraud detection, marketing). NAIC Model Bulletin scoping. State overlay identification (CO SB 24-205, CO Reg 10-1-1, TX TRAIGA, CA CCPA/ADMT, NY DFS Circular 7, CT Bulletin MC-25). Week 2 — Gap analysis + fairness testing. Control-by-control assessment against all four NAIC Model Bulletin core components: (1) AI Systems Governance + Risk Management Framework, (2) Third-Party AI Systems oversight, (3) Testing + Validation, (4) Documentation + Record-Keeping. Fairness testing methodology review. Disparate impact + proxy discrimination analysis across protected classes. Week 3 — Remediation + exam prep. Remediation roadmap with prioritized controls. Rate filing template updates + SERFF submission considerations (Enterprise tier). State DOI examination preparation package including evidence binders + interview prep.

In-scope insurance functions: Underwriting (fairness + bias testing) · Claims adjudication (AI decisioning) · Pricing (rate filing + SERFF) · Fraud detection (SIU AI use) · Marketing (adverse action notices).

Deliverables: 30-page NAIC AI Governance Readiness Report · Control gap matrix mapped to Model Bulletin core components · State-specific regulatory overlay (CO, TX, CA, NY, CT — per tier) · Fairness + bias testing methodology document · Rate filing template updates (Enterprise tier) · Prioritized remediation roadmap · State DOI exam preparation package · Board-ready executive summary.

Three tiers:

Standard ($15,000): single-state focus, up to 5 AI/ML systems, NAIC Bulletin gap analysis, 60-minute executive readout. Multi-State ($20,000): up to 3 states, up to 10 AI systems, cross-state harmonization matrix, board-ready summary. Enterprise ($25,000): 5+ states, unlimited AI system scope, SERFF rate filing support for one AI-involved filing, model risk tiering, examiner Q&A prep.

Why Kriv AI. AWS Select Tier Services Partner, Databricks Partner, and Anthropic Claude Partner Network member (April 9, 2026). The assessment leverages Amazon SageMaker Clarify (bias + fairness documentation), Amazon Bedrock (guardrails + generative AI governance), Amazon QuickSight (governance dashboards + rate filing analytics), and AWS CloudTrail (model-access audit trails) — supporting native AWS workloads without requiring migration.

Important disclaimers. This engagement provides advisory and assessment services only. It does not constitute legal advice, actuarial opinion under ASOP standards, or a regulatory filing. Clients should engage licensed counsel and credentialed actuaries for jurisdiction-specific legal interpretation and filed rate support. State adoption status of the NAIC Model Bulletin changes frequently; current scope validated at kickoff. No guarantee of regulatory approval, examination outcome, or rate filing acceptance is expressed or implied. AWS infrastructure and third-party software costs are billed separately. Anthropic CPN membership does not constitute an endorsement by Anthropic.