AI governance for Rhode Island carriers
The Rhode Island Department of Business Regulation's Insurance Division issued Insurance Bulletin Number 2024-03 on March 15, 2024, adopting the NAIC Model Bulletin on the Use of AI Systems by Insurers. It reminds every carrier holding a certificate of authority in the state that decisions affecting consumers must comply with Rhode Island insurance law, including the unfair trade practices, unfair claims settlement, and rating standards, no matter what technology produced them. The Department recognizes the NAIC's 2020 Principles on Artificial Intelligence as an appropriate source of guidance and expects each carrier to maintain a written AIS Program covering the full insurance life cycle. The bulletin also preserves the Department's authority to examine AI use under the Rhode Island Market Conduct Surveillance Act and the NAIC Market Regulation Handbook.
What Rhode Island expects from your AIS Program
Rhode Island adopted the NAIC model verbatim, so the program expectations match the national framework.
Governance
A written program with clear ownership. Senior management is accountable to the board, and a cross-functional body oversees AI across its whole life cycle.
Risk Management & Internal Controls
Controls at every stage of the model life cycle, from data sourcing through retirement, sized to the potential harm to consumers.
Third-Party AI Systems & Data
The carrier stays responsible for AI it did not build. Vendor relationships need diligence, contract rights, and the ability to produce evidence.
Documentation & Audit-Readiness
Section 4 spells out what an examiner can ask for. Treating that list as a standing requirement is what keeps a program defensible.
Legal authority
Rhode Island's Insurance Division grounds the bulletin in laws it already enforces:
- Unfair Competition and Practices ActR.I. Gen. Laws § 27-29-1 et seq.
- Unfair Claims Settlement Practices ActR.I. Gen. Laws § 27-9.1-1 et seq.
- Corporate Governance Annual Disclosure ActR.I. Gen. Laws § 27-1.2-1 et seq.
Who it applies to
The bulletin reaches every entity holding a Rhode Island certificate of authority, including:
- Property and casualty carriers
- Life and annuity carriers
- Health carriers and HMOs
- All other carriers holding a Rhode Island certificate of authority
State-specific changes: Rhode Island adopted the NAIC model substantively unchanged, including the provision that an AIS Program may rely in whole or in part on a recognized framework such as the NIST AI Risk Management Framework v1.0. A carrier building to the national framework is building to Rhode Island's expectations.
Resources for Rhode Island carriers
Start with these plain-language explainers and field guides.
What is the NAIC Model Bulletin on AI?
The NAIC Model Bulletin on the Use of AI Systems by Insurers is the template most states use to set AI governance expectations. Here is what it says and why it matters.
GuideWhat is an AIS Program?
An AI Systems Program (AIS Program) is the written program the NAIC Model Bulletin expects every carrier to maintain. Here are its four pillars and what each one requires.
GuideWhat are the NAIC AI Principles?
The NAIC AI Principles, adopted in 2020, are the foundation beneath every state AI bulletin. The five principles spell FACTS: Fair, Accountable, Compliant, Transparent, and Secure.
GuideAI in Insurance: Key Regulatory Definitions
The NAIC Model Bulletin defines the terms that carry legal weight, from AI System to Adverse Consumer Outcome to Model Drift. Here is what each one means for carriers.
ArticleAI Governance for Insurance Carriers: Where AI Runs Across the Value Chain and What Regulators Expect
Insurance AI governance across underwriting, claims, catastrophe modeling, distribution, and cyber: where AI runs today, how its failures reach the loss ratio, and the evidence state regulators now expect carriers to produce.
ArticleReinsurance AI: How Reinsurers and Rating Agencies Are Underwriting Your AI
Reinsurers and rating agencies are already forming a view of the AI in your rating and claims stack. The treaty clauses, rating methodology, case history, and renewal evidence every carrier should understand.
Rhode Island AI governance FAQs
What is Rhode Island Insurance Bulletin Number 2024-03?
Which companies have to comply in Rhode Island?
Can our AIS Program use the NIST AI Risk Management Framework?
How will Rhode Island enforce it?
How does a Rhode Island carrier get ready?
Sources
- Rhode Island DBR Insurance Division: Insurance Bulletin Number 2024-03 (March 15, 2024)
- NAIC Model Bulletin on the Use of AI Systems by Insurers (Dec 4, 2023)
- NAIC Big Data and AI (H) Working Group: model bulletin implementation map
- R.I. Gen. Laws § 27-29-1 et seq. (Unfair Competition and Practices Act)
- R.I. Gen. Laws § 27-9.1-1 et seq. (Unfair Claims Settlement Practices Act)
- R.I. Gen. Laws § 27-1.2-1 et seq. (Corporate Governance Annual Disclosure Act)
Get audit-ready for Rhode Island Bulletin 2024-03
Swept AI supervises your models and produces the AIS Program evidence Rhode Island examiners can request.