NAIC-era compliance
Re-walk every underwriting, claims, and fraud decision in front of a DOI examiner.NAIC SR 12-9 evidence. State retention agreed in week one. One tamper-evident chain.
The examiner’s questions almost never match the dashboard your model-risk team built — so Plumbline writes every underwriting decision, claims-triage routing, and fraud signal the model rendered onto a SHA-256 chain that’s already the answer. NAIC access scopes, retention windows agreed in week one, tombstoned proof of deletion, and a tamper-evident audit PDF the state-DOI examiner can re-derive without a call back to engineering.
§01 · DOI exam posture
What NAIC, SR 12-9, and state DOI ask for — and where Plumbline lives in the answer.
The examiner’s questions are almost always the same. Every row below is a real NAIC / state-DOI expectation and the Plumbline artifact the ledger already produces on the way through — no after-the-fact paste-up.
- NAIC Model Risk Management Bulletin (2024)
Every AI / ML model used for underwriting, claims, or fraud decisions is identified, classified by risk tier, and inventoried — and the inventory is re-derivable on demand.
Plumbline artifact · MRM · INVENTORIEDModel classification row + signed model card pinned to evaluation history. The MRM inventory is a query against the same chain — not a separate spreadsheet that has to be reconciled to the production record.
- SR 12-9 · AI model risk management principles
Independent validation of AI models before production deployment, with the validation evidence on the same record the production traffic runs through.
Plumbline artifact · SR 12-9 · VALIDATEDIndependent validator and ongoing monitoring ride the same row as the production decision. Validation evidence is co-signed with the model card so the audit trail is one chain, not two.
- State DOI exam handbook · model change control
Model change-control: every promotion, rollback, and param tweak is captured — the examiner reads the change history without a release tool.
Plumbline artifact · CHANGE-CONTROL · CHAINEDPromote / rollback / canary events are signed records on the same chain. The change history is a query against the ledger — anything outside the chain is a gap, not an undone change.
- NAIC Unfair Discrimination / Unfair Claims Practices
Unfair-discrimination & unfair-claims-practices safeguards: protected-class attributes never appear in cleartext on a signable inspection row.
Plumbline artifact · FAIRNESS · SCOPEDScope is set at write time. Sensitive attributes are hashed; the decision basis is on the row as reason codes, not as sensitive fields. The audit-export PDF reads reason codes without exposing the input.
- NAIC ORSA · solvency linkage
ORSA pulls evaluation evidence through the same lens as capital and risk reporting — no separate monitoring lake for modellers vs. the regulator.
Plumbline artifact · ORSA · LINKEDDrift and incident rows feed the same evaluation chain the ORSA narrative cites. There is no reconciliation step between model evidence and risk-reporting governance — they share one ledger.
- State DOI retention rules · state insurance record retention
Retention windows are contractual, not a default — records past the window cannot be silently re-fetched.
Plumbline artifact · RETENTION · WINDOWEDRetention window is set in week one with the buyer, written into the contractual addendum. Records past the window are tombstoned with a signed deletion record — the chain tells the examiner the record is gone on purpose.
- ONC-style source attribution (decline / fast-track routing analogue)
Claim-routing and fraud-decision models carry source attribution and an independent rationale the examiner can audit.
Plumbline artifact · ROUTING · ATTRIBUTEDModel + scorer version + evaluator breakdown pin the routing decision. An independent rationale evaluator runs on the same row, so the basis for the decline or fast-track is provable — not just the recommendation.
§02 · The DOI walk-back
An auto-claims triage, opened two quarters later.What the record carries — and what the examiner walks back.
- 1.What routing decision did the model surface? The claims-triage outcome (fast-track to repair network) and the underlying severity-band evaluator sit on the same row as the model version and the rationale evaluator’s score.
- 2.Was the basis for the routing on the notice? SR 12-9 and the NAIC unfair-claims-practices overlays both expect a specific rationale — the evaluator set logs reason codes inline with the input-feature snapshot, on the same record chain.
- 3.Did the calibration drift before or after? Score distribution walks back through the same ledger 30, 60, or 90 days at a time — no separate monitoring lake to reconcile against the production record.
- 4.Did protected-class fields ever appear in cleartext? Scope is set at write time. Sensitive attributes are hashed; the audit-export PDF reads reason codes without exposing the input. NAIC unfair-discrimination findings can’t come from data that was never recorded.
- 5.Has the record been edited since capture? The SHA-256 chain breaks visibly at the next record; tampering is detected at fetch, not at exam time. State-DOI model-change-control evidence is a query against the same ledger.
- 6.What does the examiner hand back to counsel? A tamper-evident audit PDF (model card + record hash + signature chain), re-derivable from the public /verify page — counsel reads the same bundle, once.
§03 · Cross-links
Read next, by buyer intent.
Reserve an insurance pilot, or send the NAIC examiner our evidence packet.
Buying for an underwriting, claims, or fraud program and want the walk-through? Drop your email and the SR 12-9 scoping checklist lands in your inbox before any contract is drawn up. Buying at the enterprise level with a state-DOI exam window already on the calendar? Send the procurement team the intake form and we'll reply with the evidence packet and a short validation offer tailored to that window.
We'll never share your email. No marketing blast — only the next-step note when a slot opens. If a state-DOI exam window is already on the calendar, mention the date on the call.
§06 · Pricing
Ready to see this on your models?
Start with the $1,000 Evidence Pilot: one workflow, one model, and 30 days ending in a replayable evidence package. Plumbline captures forward from the moment you connect, and the full pilot fee is credited toward Regulated Team.