Regulatory Assessment

SR-UW-0752 HOLD

TX · life · underwriting · decided 2026-09-27 01:48 UTC · Summit Range Life Assurance Company (fictional)

On 2026-09-27, rx-score v3 (a third-party system from RxData Labs (fictional)) produced 'decline' in a TX life underwriting transaction. Inputs included rx history, credit, consumer report, application data. A consumer report was used. A human reviewed the output by a underwriter. The outcome was adverse to the consumer; no notice to the consumer is recorded. RegBench applied 10 rule(s) in force on 2026-09-27 and recorded 2 finding(s); the most serious is 'Adverse action based on a consumer report with no FCRA notice recorded' (high, L0).

HOLD: 2 finding(s) under rules 2026.10+c4982313, corpus 2026-10-30-9c5dad5a. Recommended hold for the carrier's compliance review before the outcome is communicated; the carrier decides.

Coverage: supported. 5 state-specific and 2 general black-letter rule(s) applied to this TX life underwriting transaction. Only the configured checks were run; a result is not a legal opinion on compliance. 10 of 30 rules applied.

Evidence (missing). Missing evidence: ai_system.governance_attested, ai_system.model_doc_ref, ai_system.testing_report_ref. Supplied but unverified: inputs.data_source_refs.

Findings (2)

high L0 black letter hold exhibit C us.fcra.adverse-action-notice

Adverse action based on a consumer report with no FCRA notice recorded

Finding. The decision was adverse to the consumer and was based in whole or in part on a consumer report, but no adverse action notice is recorded on the transaction.

Basis. FCRA § 615(a) requires the user of a consumer report to notify the consumer of an adverse action, identify the consumer reporting agency, state that the agency did not make the decision, and explain the consumer's rights to a free report and to dispute. A denial, increase in charge or unfavorable change in insurance terms in connection with underwriting is an adverse action under § 603(k)(1)(B)(i).

Required action. Hold the outcome for compliance review; generate the notice with every required element before the decision is communicated, and record notice_sent_at on the transaction.

Excerpt: us-fcra-1681m-a · federal statute (public domain) · in force from 1971-04-25

"If any person takes any adverse action with respect to any consumer that is based in whole or in part on any information contained in a consumer report, the person shall (1) provide oral, written, or electronic notice of the adverse action to the consumer; (2) provide to the consumer written or electronic disclosure of a numerical credit score [used in taking the adverse action, with the information required by § 1681g(f)(1)]; (3) provide to the consumer orally, in writing, or electronically (A) the name, address, and telephone number of the consumer reporting agency ... that furnished the report ... and (B) a statement that the consumer reporting agency did not make the decision to take the adverse action and is unable to provide the consumer the specific reasons why the adverse action was taken; and (4) provide ... notice of the consumer's right (A) to obtain ... a free copy of a consumer report ... within 60 days ... and (B) to dispute ... the accuracy or completeness of any information in a consumer report."

Excerpt: us-fcra-1681a-k-1-b-i · federal statute (public domain) · in force from 1997-09-30

"a denial or cancellation of, an increase in any charge for, or a reduction or other adverse or unfavorable change in the terms of coverage or amount of, any insurance, existing or applied for, in connection with the underwriting of insurance."

medium L5 precedent advisory flag exhibit C precedent.ai-flagged-cancellation-without-notice

AI-flagged non-renewal or decline with no notice recorded (pattern of the 2026 Pennsylvania agreement)

Finding. An AI system flagged the risk and the policy was declined or not renewed without a notice to the consumer being recorded; this is the fact pattern of the Pennsylvania Attorney General's 2026 agreement with an auto insurer over an AI-enabled underwriting review tool.

Basis. Precedent: as reported, the insurer agreed to follow the Pennsylvania Insurance Department's AI guidance, to extend document deadlines and to accept additional proof after a cancellation without adequate notice. Regulators in other states read the same headlines; the pattern deserves a reviewer's attention wherever it appears.

Required action. Confirm the notice and document deadlines before the cancellation or decline takes effect; record the notice on the transaction.

Excerpt: precedent-pa-geico-2026 · enforcement precedent reported by secondary sources; persuasive only · in force from 2026-05-22

Announced by Pennsylvania Attorney General Dave Sunday on 22 May 2026: a new policyholder in West Philadelphia was selected by an underwriting-review tool with artificial-intelligence features during the insurer's 60-day review of new policyholders and lost coverage without realising it after believing she had sent the requested residency documents. GEICO agreed to act in line with the Pennsylvania Insurance Department's guidance on insurers' use of AI, to extend the document-submission period for selected new policyholders by one week, to accept one form of residency verification (a current driver's licence suffices when its address matches the policy), and to train customer-service staff on the revised requirements. No admission of wrongdoing; no monetary term reported.

Point in time

Law as of
2026-09-27
Rules version
2026.10+c4982313
Corpus snapshot
2026-10-30-9c5dad5a
Engine
regbench-engine/0.5.0 · deterministic-1
Fingerprint
f07a1422a452b905b2ad48c6 (pattern grouping, not an integrity check)
Input digest
fc4ece1db46c3e56fd344c2e49e24476a50a1b93cb3f3abb0923aaeafaeb5f6f
Evaluated
2026-10-31 05:42:54 UTC
Exhibit C case file
yes

Ledger

Entry
#6255 · assessment · recorded 2026-09-27T01:49:35+00:00
Hash
328783c52b8780698c75338087f7afe20fa9198f6e512b3181c145fa3337d309
Previous
ca7bee8b37e34c6b8caf7abe1423bfe6b91a276481f422f93938c696e3a8d2d9
Stored copy intact
yes, hashes match
Assessed input intact
yes, revision 1 matches the input digest

Verify the whole chain Case file JSON

Carrier review

Open since 2026-09-27T01:49:35+00:00. The carrier's reviewer decides; RegBench records the decision on the ledger.

Sign in as operator to record the review here; a carrier records it with its own API key.

Recorded facts revision 1

As asserted by the carrier. References are recorded, not verified: RegBench holds no copy of the documents they name.

AI system
rx-score v3 · third party (RxData Labs (fictional)) · high-risk class: underwriting
Governance attested
False
Testing report
none recorded
Model documentation
none recorded
Feature classes
rx_history, credit, consumer_report, application_data
Protected factors used
none
External data (ECDIS)
False
Consumer report / credit
True / True
Data sources
vendor://rxdata/score, cra://demo-bureau/attributes
Decision
decline · score 0.882 · codes RX4, CR2
Human review
yes (underwriter)
Adverse to consumer
True
Notice
not recorded · reasons: False · specific: False · external data disclosed: False
Appeal channel
–
Consumer token
tok_1e3e464d78