HI| Memorandum 2025-13A, issues by the Hawaii Insurance Division, sets expectations for Hawaii-authorized insurers’ development, governance, and oversight of AI systems used in regulated insurance activities, emphasizing compliance with existing unfair trade practice, corporate governance, rate, and market conduct laws, and outlining the documentation the Division may request during investigations or examinations related to AI use.
Key Points Covered:
- Section 1 – Introduction, Background, and Legislative Authority: Explains AI’s growing role across the insurance lifecycle, associated benefits and risks, and aligns expectations with NAIC AI Principles.
- Section 2 – Definitions: Defines key terms including Adverse Consumer Outcome, Algorithm, Artificial Intelligence, AI System, Generative AI, Machine Learning, Model Drift, Predictive Model, and Third-Party for purposes of the memo.
- Section 3 – Regulatory Guidance and Expectations: States that all AI-supported decisions subject to insurance regulation must meet existing legal standards and that insurers must develop, implement, and maintain a written AIS Program for responsible AI use.
- Section 4 – Regulatory Oversight and Examination Considerations: Describes how the Division may examine an insurer’s AI use in investigations or market conduct actions, regardless of whether a formal AIS Program exists.