Exhibit D
The documentation-and-record-keeping section of the NAIC AI Evaluation Tool, covering evidence insurers must retain about AI systems and decisions.
Exhibit D of the NAIC AI Evaluation Tool addresses documentation and record-keeping. It asks insurers to maintain evidence that demonstrates compliance with the governance, risk-management, and acquisition requirements in the other exhibits.
Key documentation themes include:
- Policies and procedures related to AI governance.
- Risk assessments and validation results.
- Vendor contracts and due-diligence records.
- Training materials and evidence of staff completion.
- Records of AI-related decisions and escalations.
Exhibit D is where examiners check whether an insurer can prove what it claims. Without contemporaneous documentation, governance and risk-management controls are hard to demonstrate. Our NAIC AI Evaluation Tool guide lists the documents that typically satisfy each requirement.