NYDFS

The New York State Department of Financial Services (NYDFS) regulates banks and insurance companies operating in New York. It is one of the most influential state financial regulators in the U.S. because of the size of the New York market and the extraterritorial reach of its rules.

In July 2024, NYDFS issued Insurance Circular Letter No. 7, which requires insurers using AI or external consumer data in underwriting and pricing to show that the tools do not produce unfairly discriminatory or inaccurate outcomes. The letter’s proxy test has become a national reference point for carriers that write in New York.

NYDFS guidance often functions as a de facto national standard. A program built to satisfy it is likely to satisfy or exceed requirements in many other states. See our guides to NYDFS Circular Letter No. 7 and its glossary entry.