Exhibit C
The high-risk model section of the NAIC AI Systems Evaluation Tool: what each high-risk model is, how it was validated, and when it was last tested.
Exhibit C of the NAIC AI Systems Evaluation Tool is titled “High-Risk AI Systems Details.” It collects detail on each model in that class, which the purpose line illustrates with models making automated decisions that could cause an adverse consumer outcome or a material financial or financial-reporting impact. The illustration is not the entry test: the tool leaves the risk criteria to the company, so which systems count as high risk is the insurer’s own assessment, which regulators may then probe.
The exhibit then asks thirteen things about each model, among them what it is, who built it, how the company rates its risk, what output testing and validation stand behind it, model drift included, how it is reviewed for compliance with applicable state and federal law, and the date of its last test.
The request insurers tend not to expect on a form is the one asking about regulatory actions taken against the company over that model. Because many insurers use vendor-built AI, Exhibit C also overlaps with vendor oversight: the exhibit asks for the vendor’s name by default. See our NAIC AI Evaluation Tool guide for the complete walkthrough.