Amanda Crawford was appointed by Governor Greg Abbott in January 2026 to serve as the new commissioner of insurance for the Texas Department of Insurance (TDI), officially stepping into the role on February 3. She succeeds Cassie Brown, who retired after leading TDI for four years.
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December 2025 Developments in the Insurance Industry
By Paige Waters
Please take note of the following December 2025 developments in the insurance industry.
- NAIC Elections: On December 11, 2025, the National Association of Insurance Commissioners (NAIC) elected the following chief state insurance regulators to serve as officers in 2026, effective January 1, 2026.
- President: Virginia Insurance Commissioner Scott A. White.
- President-Elect: Rhode Island Department of Business Regulation
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AI Definitions a Challenge for Liability Insurers’ Exclusions
This article provides an excellent overview of the challenges insurers face in drafting policy language that keeps pace with the fast-evolving use of artificial intelligence. The author discusses how multiple insurers faced the challenge of defining what is “artificial intelligence” or “generative AI” by consulting with various industry sources. I asked ChatGPT how it would…
Colorado Division of Insurance Expands AI Governance and Framework Regulation to Private Passenger Auto and Health Benefit Plan Insurers
On August 20, 2025, the Colorado Division of Insurance (Division) amended Regulation 10-1-1 to expand its existing limited applicability to insurers offering individual life insurance to apply to insurers offering private passenger auto and health benefit plans effective October 15, 2025. Evidence of compliance with the amended regulation must be made available to the Division…
Red Teaming Is an Effective Tool for Insurer Assessment of AI Risks
The insurance industry is facing increased scrutiny from insurance regulators related to its use of artificial intelligence (AI). Red teaming can be leveraged to address some of the risks associated with an insurer’s use of AI. The U.S. Department of Commerce’s National Institute of Standards and Technology (NIST) defines a “red team”[1] as:…
Pennsylvania Enacts New Digital Forgery Law
On July 7, 2025, Pennsylvania Governor Josh Shapiro enacted a new Digital Forgery Law by signing SB 649 into law, which will take effect in 60 days. SB 649 creates “new criminal penalties for anyone who uses artificial intelligence (AI) to produce non-consensual “forged digital likenesses” — like deepfakes or voice clones — to defraud or…
NAIC Responds to Proposed 10-Year Moratorium on State Regulation of AI in One Big Beautiful Bill Act
There is a proposed 10-year moratorium on the enforcement of state laws that regulate artificial intelligence (AI) contained in Section 43201(c) of H.R.1 – One Big Beautiful Bill Act. The National Association of Insurance Commissioners (NAIC) recently submitted its response to members of the U.S. Senate (attached at the link), raising various concerns that…
Wisconsin Becomes the 24th State to Adopt the NAIC Model Bulletin on the Use of AIS in Insurance
By Paige Waters
On March 18, Wisconsin Insurance Commissioner Nathan Houdek issued Wisconsin’s new bulletin on the use of artificial intelligence systems (AIS) in insurance, becoming the 24th state to adopt the NAIC Model Bulletin on the Use of Artificial Intelligence Systems by Insurers. A copy of the bulletin is found at this link.…
New Jersey Adopts Bulletin on AI Use in Insurance
By Paige Waters
On February 11, New Jersey Banking and Insurance Commissioner Zimmerman issued Bulletin 25-03 regarding the use of artificial intelligence systems (AIS) in insurance, applicable to all insurers authorized or admitted in New Jersey. New Jersey becomes the 23rd state to adopt the bulletin based on the NAIC Model Act on the Use of AIS by…
Delaware Insurance Commissioner Navarro Issues Bulletin No. 148 Re: Use of Artificial Intelligence Systems in Insurance
By Paige Waters
On February 5, Delaware joined 21 jurisdictions who adopted guidance similar to the NAIC Model Bulletin on the Use of Artificial Intelligence (AI) Systems by Insurers in 2024, and four additional jurisdictions have otherwise issued guidance or regulation.In addition to other detailed guidance, Bulletin No. 148 also reiterates the Delaware Department of Insurance’s authority to…