# Asrow Assembly Statement on AI in Insurance (Dec 2025): Statement by DFS Acting Superintendent Kaitlin Asrow at the NYS Assembly Hearing on the Use of Artificial Intelligence Systems in Insurance Underwriting and Pricing

Source: https://www.bankingnewsai.com/ai-regulation/documents/ny-dfs-asrow-assembly-statement-2025-12-16-ai-insurance
Last updated: Aug 26, 2026

On December 16, 2025, Acting Superintendent Kaitlin Asrow told the New York Assembly's Insurance and Science and Technology committees that DFS applies existing, technology-neutral law to AI — 'the core regulatory obligations are the same for manual processes as they are for AI models' — and that it has integrated review of new AI systems and datasets into its examinations. She described Insurance Circular Letter No. 7 (2024), the May 2024 virtual-currency chatbot guidance, and the October 2024 AI cybersecurity letter as DFS's AI framework, said she saw no immediate need for additional AI rules, but acknowledged room for specific AI requirements as new risks arise.

## At a glance

| Field | Value |
| --- | --- |
| Authority | [NY DFS](https://www.bankingnewsai.com/ai-regulation/ny-dfs) |
| Type | Speech |
| Status | Final |
| Published | Dec 16, 2025 |
| Applies to | Statement of DFS supervisory philosophy on AI; relevant to all DFS-regulated banks, insurers, and licensees |
| Official text | https://www.dfs.ny.gov/reports_and_publications/press_releases/pr20251216 |

## Key points

- DFS's stated approach: technology-neutral enforcement of existing anti-discrimination, consumer-protection, and cybersecurity law rather than AI-specific rulemaking.
- Examinations now include review of new AI systems and external data sources deployed by regulated entities.
- Cites three pillars: Circular Letter No. 7 (2024) on AI in insurance underwriting and pricing, the May 30, 2024 virtual-currency customer service guidance on AI chatbots, and the October 16, 2024 AI cybersecurity Industry Letter.
- No immediate plans for further AI rules; 'guidance and circular letters' remain the vehicle, with AI-specific requirements possible 'as new risks arise'.
- Asrow references her prior role at the Federal Reserve supervising banks' use of technology, signalling continuity of the bank-supervision lens in DFS's AI work.

## What changed for banks

This is the clearest public statement of where DFS is going on AI after Adrienne Harris's departure: no AI rulebook, but AI systems are already inside the examination scope. For banks it means AI governance evidence — model inventories, testing, vendor oversight — should be exam-ready under existing Banking Law and Part 500 authorities, not deferred until a rule exists.

## Use cases it governs

- [AI governance (general)](https://www.bankingnewsai.com/ai-regulation/by-use-case#governance-general)
- [Fair lending & discrimination](https://www.bankingnewsai.com/ai-regulation/by-use-case#fair-lending)
- [Customer-facing chatbots](https://www.bankingnewsai.com/ai-regulation/by-use-case#customer-chatbots)
- [Cybersecurity](https://www.bankingnewsai.com/ai-regulation/by-use-case#cybersecurity)

## FAQ

### Is NYDFS planning an AI-specific regulation?

Not as of December 2025. Acting Superintendent Asrow told the Assembly that DFS relies on technology-neutral law plus guidance and circular letters, while leaving room for specific AI requirements if new risks emerge.

### Does NYDFS examine banks' AI systems today?

Yes. Asrow stated DFS has integrated reviews of new AI systems and datasets into its supervisory approach, and its October 2024 letter makes AI risk part of the Part 500 examination scope.

## Related documents

- [DFS Frontier AI Models Industry Letter (May 2026)](https://www.bankingnewsai.com/ai-regulation/documents/ny-dfs-industry-letter-2026-05-21-frontier-ai-models) — Heightened Cybersecurity Risks Associated with Frontier AI Models (May 21, 2026)
- [DFS Heightened Threat Environment Guidance (May 2026)](https://www.bankingnewsai.com/ai-regulation/documents/ny-dfs-industry-letter-2026-05-21-heightened-threat-environment) — Guidance on Measures Regulated Entities Should Consider in a Heightened Cybersecurity Threat Environment (May 21, 2026)
- [New York RAISE Act](https://www.bankingnewsai.com/ai-regulation/documents/ny-raise-act) — Responsible AI Safety and Education (RAISE) Act, General Business Law Article 44-B (Chapter 699 of the Laws of 2025, as amended by Chapter 96 of the Laws of 2026) (Dec 19, 2025)
- [DFS AI Cybersecurity Industry Letter (Oct 2024)](https://www.bankingnewsai.com/ai-regulation/documents/ny-dfs-industry-letter-2024-10-16-ai-cyber-risks) — Cybersecurity Risks Arising from Artificial Intelligence and Strategies to Combat Related Risks (Oct 16, 2024)
- [Insurance Circular Letter No. 7 (2024)](https://www.bankingnewsai.com/ai-regulation/documents/ny-dfs-insurance-circular-letter-2024-07) — Use of Artificial Intelligence Systems and External Consumer Data and Information Sources in Insurance Underwriting and Pricing (Jul 11, 2024)
- [DFS Virtual Currency Customer Service Guidance (May 2024)](https://www.bankingnewsai.com/ai-regulation/documents/ny-dfs-industry-letter-2024-05-30-vce-customer-service) — Guidance Regarding Customer Service Requests and Complaints (Virtual Currency Entities) (May 30, 2024)
- [DFS Proposed AI Insurance Circular Letter (Jan 2024)](https://www.bankingnewsai.com/ai-regulation/documents/ny-dfs-proposed-insurance-circular-letter-2024-01) — Proposed Insurance Circular Letter on the Use of Artificial Intelligence Systems and External Consumer Data and Information Sources in Insurance Underwriting and Pricing (Jan 17, 2024)
- [23 NYCRR Part 500](https://www.bankingnewsai.com/ai-regulation/documents/ny-dfs-23-nycrr-part-500) — Cybersecurity Requirements for Financial Services Companies (Second Amendment) (Nov 1, 2023)

Last reviewed Aug 26, 2026. Cite the official text (https://www.dfs.ny.gov/reports_and_publications/press_releases/pr20251216) for the rule and this page for the summary and dates.

---

Canonical page: https://www.bankingnewsai.com/ai-regulation/documents/ny-dfs-asrow-assembly-statement-2025-12-16-ai-insurance
Part of [BankingNewsAI](https://www.bankingnewsai.com/) — a free daily brief on AI in banking, an AI regulation tracker (41 authorities, 237 documents) and AI-strategy profiles of the 120 largest US banks. Markdown versions of every reference page: append `.md` to the page URL; index at https://www.bankingnewsai.com/llms.txt.