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Underwriting AI silently over-declined one applicant group. This is the $499 Snapshot that found it.

Casual-glance overview here. Every deeper claim is a click away: full sample report, each cited regulation, every chart, every finding — and "how does this help me?" companion pages for each.

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The 4-number quick verdict

Determination

Category C

High-severity drift events

I3 decline-lane rate

11% → 62%

Days to detect (silent)

60+

What does Category C actually mean? →

What happened in one paragraph

A mid-market P&C carrier's AI underwriting-decision classifier silently over-routed I3 (age 25-45, mid credit tier, mixed urban/lower-income zip) into the decline / refer-SIU lane. Aggregate quote-to-bind ratio and loss ratio stayed within normal bands. The differential was visible only through per-group distributional-shape analysis by an independent verifier. Under the NAIC AI Model Bulletin (adopted by 39+ state DOIs) and FCRA 15 USC 1681m, every affected decision now sits inside an adverse-action-notice reconstruction duty.

Read the full scenario walkthrough →

Life insurance carrier? See the Colorado-specific variant. Colorado SB 21-169 + 3 CCR 702-10 (Reg 10-1-1 + 10-1-2) put ECDIS + algorithm testing on an annual officer-attestation clock. The life-co one-pager reads the same shape but maps line-by-line to the Colorado regulation text. Life-co / Colorado one-pager →

The three charts (each linked to its own deep-dive)

Chart 1 · Deep dive Rolling mean by applicant group Where the silent I3 divergence begins. What the eye sees vs what the underwriting dashboard reported. Chart 2 · Deep dive Baseline vs recent distribution I3 mass shifted RIGHT (into decline / refer-SIU lane). How to read the shape shift. Chart 3 · Deep dive Lane rate per applicant group I3 decline / refer-SIU rate rose sharply while others stayed stable. The one pattern DOI examiners look for.

Regulations applied — each on its own page

Every cited framework has a dedicated subpage with the actual regulatory text, plain-English translation, what the Snapshot shows against it, and a "how does this help me?" benefit companion.

Regulation NAIC AI Model Bulletin Adopted by 39+ state DOIs 2024-2026. The cross-state expectation of independent AI validation. Regulation NY DFS Circular Letter No. 7 (2024) Governance + independent validation for AI + external consumer data used by NY-authorized insurers. Regulation Colorado SB 21-169 + Reg 10-1-1 ECDIS + algorithm testing rule. Annual officer-attestation. Extended to auto+home in 2026 rulemaking. Regulation CA Insurance Code 790.03(f) Unfair discrimination in insurance rating + AI-driven underwriting. CA DOI market-conduct authority. Regulation FCRA 15 USC 1681 Adverse-action notice + specific-reason disclosure for AI-influenced underwriting decisions. Regulation State AG AI-in-Insurance enforcement WA AG multi-carrier settlement 2025. TX AG active 2026. Consumer-protection lever on AI underwriting. Regulation NCOIL AI Systems Model Act Adopted 2025. Being written into state legislation. The next wave of state-level AI insurance law. Regulation FTC Section 5 Unfair or deceptive practices. Federal consumer-AI transparency stance on undisclosed adverse-impact. Regulation (shared) HIPAA 45 CFR 164 Applies to health-insurance carriers using AI on PHI. Retention of AI-decision records. Regulation (shared) NIST AI RMF 1.0 GOVERN / MAP / MEASURE / MANAGE. Voluntary but load-bearing baseline cited by state DOIs.

Findings + methodology deep dives

Methodology How Category C is derived Category A / B / C decision logic. Why 9 high-severity events + group-differential = C. Methodology Counterparty-question rehearsal The 5-decision reproducibility drill your GC / DOI liaison / defense counsel will thank you for. Methodology Independent-verifier declaration Why the control plane cannot reside within the entity being regulated.

The full records

Full Snapshot Report (markdown) Executive One-Pager (markdown) Life-Co / Colorado One-Pager (markdown) Long-form single-page view

$499. Three business days. Your carrier's actual Snapshot.

Same structure as this sample. Your carrier's data, your AI system, your state DOI footprint, your regulatory citations. Below procurement threshold. Report PDF via email.

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