AI governance for West Virginia carriers
The Offices of the West Virginia Insurance Commissioner issued Insurance Bulletin No. 24-06 on August 9, 2024, based on the NAIC Model Bulletin on the Use of AI Systems by Insurers. It reminds carriers that decisions or actions impacting consumers, including those supported by AI Systems, must comply with all applicable West Virginia insurance laws, including those addressing unfair trade practices, unfair claims settlement practices, and unfair discrimination. The OIC recognizes the NAIC's 2020 Principles on Artificial Intelligence as an appropriate source of guidance and recommends that every carrier maintain a written AIS Program across the full insurance life cycle. The bulletin keeps the AIS Program guidelines intact while presenting them as expectations the OIC recommends rather than mandates.
What West Virginia expects from your AIS Program
West Virginia adopted the NAIC model with some changes. The four pillars below are the shared foundation.
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
The West Virginia OIC grounds the bulletin in laws it already enforces:
- Unfair Trade PracticesW. Va. Code §33-11-1 et seq.
- Rates and Rating OrganizationsW. Va. Code §33-20-1 et seq.
- Corporate Governance Annual Disclosure ActW. Va. Code §33-52-1 et seq.
Who it applies to
The bulletin reaches every entity holding a West Virginia certificate of authority, including:
- Property and casualty carriers
- Life and annuity carriers
- Health carriers and HMOs
- All carriers authorized to do business in West Virginia
State-specific changes: West Virginia tracks the NAIC model closely but does not adopt it verbatim: it trims the introductory legislative-authority framing, folds the examination considerations into a single closing paragraph, and presents the AIS Program as guidelines the OIC recommends. Like the model, it permits the program to rely on a recognized framework such as the NIST AI Risk Management Framework v1.0.
Resources for West Virginia 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.
West Virginia AI governance FAQs
What is West Virginia Insurance Bulletin No. 24-06?
Which companies have to comply in West Virginia?
Did West Virginia adopt the NAIC model word for word?
How will West Virginia enforce it?
How does a West Virginia carrier get ready?
Sources
- West Virginia OIC: Insurance Bulletin No. 24-06 (August 9, 2024)
- NAIC Big Data and AI (H) Working Group implementation map (West Virginia: Bulletin 24-06, Adopted August 9, 2024)
- NAIC Model Bulletin on the Use of AI Systems by Insurers (Dec 4, 2023)
- W. Va. Code §33-11-1 et seq. (Unfair Trade Practices)
- W. Va. Code §33-20-1 et seq. (Rates and Rating Organizations)
- W. Va. Code §33-52-1 et seq. (Corporate Governance Annual Disclosure Act)
Get audit-ready for West Virginia Bulletin 24-06
Swept AI supervises your models and produces the AIS Program evidence West Virginia examiners can request.