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On December 4, 2023, the National Association of Insurance Commissioners adopted a model bulletin entitled “Use of Artificial Intelligence Systems by Insurers” which sets forth principles-based standards for the practices that insurers that use AI and are licensed in any state that has adopted the Bulletin are expected to adopt. The Bulletin’s requirements are principles-based and are intended to build upon, and not displace or supersede, existing requirements under state insurance laws. The Bulletin does not attempt to prescribe any specific quantitative metrics, parameters or scenarios for testing the outcomes of an insurer’s use of AI.