Eleven letters against one clause

Eleven comment letters landed on the NAIC’s vendor framework by its August 5 close, and the working group carried them to Columbus without putting the framework to a vote. The fight has moved off registration and onto who absorbs the loss when a vendor stops cooperating.

This week’s story: the framework fight has narrowed to one clause

The Third-Party Data and Models (H) Working Group met August 12 in Columbus with one substantive item: discuss the P&C pricing and underwriting framework it exposed July 8. The packet holds that framework unchanged, plus the eleven letters; the only adoption item was the previous meeting’s minutes.

The first exposure drew 23 letters, and mandatory registration went voluntary. This round converges on the clause that replaced it: a regulator may prohibit insurers from using a vendor’s data or model if the vendor does not supply what is asked. The National Alliance of Life Companies puts the problem in a section heading, “A Registry That Is Voluntary for Vendors Is Not Voluntary for Carriers.” The refusal is the vendor’s, the lost tool is yours, and replacing one is, in the letter’s words, a months-long project. Its asks: direct notice to affected insurers, a transition period, and no exam consequence for a vendor’s non-cooperation. NAMIC asked the working group to revise its charges outright. TransUnion wants the customer-relationship disclosure gone.

Read the signature blocks too. NALC writes life and health, BCBSA filed only a watch note, and both are there because the working group may extend the framework to other lines. The scope on the page is not the scope being argued over.

None of the eleven asks to loosen what lands on you: validating for your own book and contractual access to model information sit outside the fight. The registry mechanics, from the July 8 draft: our walk-through of what vendors would file and who gets to see it.

What to do this week

• Read the two letters most likely to change the draft: NALC at pages 47 to 50 of the meeting packet, NAMIC at 51 to 54. They are the positions your vendors will quote back at you.
• Ask each outside pricing or underwriting vendor, in writing, whether it commented and whether it would register as drafted. The answer goes in the vendor file; the silence goes there too.
• Time the swap. NALC calls replacing an embedded data source or model a months-long project. Run your own estimate for your most embedded vendor model and write it into the vendor file.

On the Docket

• August 13, 2026: The Big Data and AI (H) Working Group meets at 1:00 p.m. ET: an update on the AI Risk Evaluation Supplement pilot, plus an AM Best presentation on AI governance. Anyone whose exam file may one day include these exhibits. NAIC agenda
• September 1, 2026: Comment window closes on the ASOP No. 45 and No. 49 revisions. Health writers, and anyone signing risk-adjustment actuarial work. Actuarial Standards Board
• September 2026: The 12-state pilot’s window for using the evaluation tool runs through September; the tool is then updated and reissued for review. Pilot-state carriers first, everyone else at adoption. NAIC pilot summary
• November 2026: The updated tool goes before the Fall National Meeting for adoption consideration. Every carrier; an adopted supplement is what a 2027 examiner picks up. NAIC pilot summary

This week in brief

Governance

Allstate is building ALLIE, an in-house large language model on the 40 petabytes behind its 250 analytical models, with pricing and claims among the stated targets. A carrier that builds is also, in NALC’s words to the NAIC, outside the registry entirely. Insurance Journal

Irregular, the evaluation firm that tests for Meta, Anthropic, and OpenAI, is where models from all three reached the open internet. Model diligence rests on the evaluation report, and our account of the concentration underneath works through what that means. OpenAI

Business Lines

CCC reported on August 6 that bodily injury payouts passed auto physical damage for the first time, with generative AI, in its analyst’s words “more of a force multiplier rather than the sole influence,” assembling demand packages in hours. That software answers to no insurance regulator, while the adjuster’s side of the same file sits under Exhibit C. CCC

Sixfold’s survey of 543 underwriting professionals found 72% of underwriters would factor a company’s AI capabilities into a career move, and 77% of executives worry about losing people over it. The error bars run five points either way, wide enough that several of the headline gaps are not gaps at all. Sixfold

From the Guides

A vendor that registers hands regulators a map of its insurer customers, and a vendor that refuses hands the insurer a replacement project. Our AI vendor risk assessment checklist covers the intake side: the twenty questions to ask before the contract is signed.

The letters run 47 pages, and one of them may be arguing your position without your name on it. If a letter deserves a close read in a future issue, reply to the email this issue arrived in and name it. Every reply gets read.

– The Editor, InsureAI Wire