financial · NAIC Model Bulletin · EU AI Act Annex III · Colorado AI Act
AI Liability Insurance
Annex III 5(c): life/health pricing AI = high-risk — NAIC mirror for US market conduct
—CMA agent liability guidance (live)
Regulatory exposure — commonly overlooked:
The insurer examining you uses AI they cannot govern — Exhibit D applies both directions. · CMA: you are liable for your AI agent like an employee — applies to every agentic commerce vertical.
TAM / Exposure
$50B+ US P&C · AI governance exam on insurer AND insured
Insurance lines
AI liability · E&O · D&O
Exhibit authority
UK CMA Agent Liability Pack — NAIC Exhibit D — Insurer + Insured Mirror Pack
Global leaders
NAIC · Munich Re · Swiss Re · AmTrust · Counterpart · CMA · ICO · FCA
Dual exam weapon
Same Exhibit A–D feeds market conduct AND financial exams — compounded findings.