On July 11, 2024, the New York State Department of Financial Services issued Circular Letter No. 2024-7, entitled “Use of Artificial Intelligence Systems and External Consumer Data and Information Sources in Insurance Underwriting and Pricing”, which sets forth guidance for insurers licensed in New York that use artificial intelligence systems and external consumer data and information sources for underwriting and pricing purposes. While the circular letter is generally consistent with the initial draft circular letter that was released for public comment in January 2024, it includes modifications and clarifications to certain requirements in response to comments. This memorandum focuses on the most significant revisions and clarifications included in the circular letter.