On July 11, 2024, the New York Department of Financial Services (NY DFS) released its final circular letter on the use of external consumer data and information sources (ECDIS), AI systems, and other predictive models in underwriting and pricing insurance policies and annuity contracts. A circular letter is not a regulation per se, but rather a formalized interpretation of existing laws and regulations by the NY DFS. The finalized guidance comes after the NY DFS sought input on its proposed circular letter, which was published in January 2024.