Industry Updates
NALC Comment Letter, Risk-Based Regulatory Framework for Third-Party Data and Model Vendors
February 6, 2026
Submitted electronically to Jason Lapham, Chair, Third Party Data and Models (H) Working Group, National Association of Insurance Commissioners
Chairman Lapham,
This comment letter is submitted on behalf of the National Alliance of Life Companies (NALC). We welcome the opportunity to comment on the Working Group’s Risk-Based Regulatory Framework for Third-Party Data and Model Vendors exposure draft (the “Exposure Draft”).
The NALC is a national trade association whose members include smaller, mid-sized and specialty life and health insurers. The NALC was formed in 1992 to address concerns that existing trade associations were not adequately representing the interests of member companies and their policyholders. Unlike many larger life insurers, NALC members serve regional markets and specific demographics, including working-class families, rural communities, and small business owners. Our members and their policyholders depend upon regulatory frameworks that are appropriately scaled, do not create artificial barriers, and preserve competitive market dynamics.
We appreciate the work that the Working Group and other NAIC committees are doing to develop regulatory frameworks applicable to insurance carrier use of AI and advanced analytics. The NALC supports regulators having the tools they need to ensure that insurance companies’ use of AI Systems complies with applicable state insurance laws and regulations.
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