On January 17, 2024, the NYDFS released for public comment a draft circular letter, entitled “Use of Artificial Intelligence Systems and External Consumer Data and Information Sources in Insurance Underwriting and Pricing,” which sets forth proposed guidance for insurers licensed in New York that use artificial intelligence systems (AIS) and external consumer data and information sources (ECDIS) for underwriting and pricing purposes. The draft circular letter applies to all insurers licensed in New York (including both New York domestic insurers and insurers domiciled in other states that have New York licenses) and includes a variety of proposed requirements, including with respect to: (i) ensuring that use of AIS and ECDIS does not result in unfair discrimination or violate the New York Insurance Law; (ii) conducting quantitative and qualitative testing for unfair or unlawful discrimination; (iii) governance, risk management and internal controls standards; (iv) standards for oversight of AIS and ECDIS provided or deployed by third parties; and (v) disclosures to insureds and applicants.