Regulatory Assessment

BB-UW-0084 FLAG

TX · auto · underwriting · decided 2026-09-29 16:16 UTC · Bluebonnet Mutual Insurance Company (fictional)

On 2026-09-29, uw-triage v2.4 (an internally developed system) produced 'refer' in a TX auto underwriting transaction. Inputs included application data, claims history, consumer report, credit, geography. A consumer report was used. A human reviewed the output by a underwriter. The outcome was not adverse to the consumer. RegBench applied 11 rule(s) in force on 2026-09-29 and recorded 2 finding(s); the most serious is 'Consumer report used with no data source reference recorded' (low, L0).

FLAG: 2 finding(s) under rules 2026.10+c4982313, corpus 2026-10-30-9c5dad5a. Routed to the carrier's compliance reviewer with cited findings.

Coverage: supported. 6 state-specific and 2 general black-letter rule(s) applied to this TX auto underwriting transaction. Only the configured checks were run; a result is not a legal opinion on compliance. 11 of 30 rules applied.

Evidence (carrier asserted). Supplied by the carrier and not verified by RegBench: ai_system.governance_attested, ai_system.model_doc_ref, ai_system.testing_report_ref.

Findings (2)

low L0 black letter flag exhibit C, D us.fcra.permissible-purpose-undocumented

Consumer report used with no data source reference recorded

Finding. A consumer report was used but the transaction records no data source reference, so the permissible purpose and the furnishing agency cannot be evidenced from the case file.

Basis. FCRA § 604(a)(3)(C) permits use of a consumer report in connection with the underwriting of insurance; the case file should identify the report and the agency so the permissible purpose and any later § 615 notice can be evidenced.

Required action. Record the consumer reporting agency and report reference on the transaction.

15 U.S.C. § 1681b(a)(3)(C) — permissible purpose: underwriting of insurance verified

Excerpt: us-fcra-1681b-a-3-c · federal statute (public domain) · in force from 1971-04-25

"[A]ny consumer reporting agency may furnish a consumer report under the following circumstances and no other: ... (3) To a person which it has reason to believe ... (C) intends to use the information in connection with the underwriting of insurance involving the consumer".

low L4 guidance flag exhibit D tx.tdi.third-party-data-source-unrecorded

Third-party data used with no source recorded

Finding. The decision used data from a third party, and the transaction records no data source, so the accuracy of the data cannot be traced or corrected.

Basis. Bulletin B-0036-20 reminds regulated entities that they "are responsible for the accuracy of the data used in rating, underwriting, and claims handling" even when "the data is provided by a third party", and encourages a way for policyholders to review and correct it.

Required action. Record the data source reference so the data can be traced and corrected.

TDI Commissioner's Bulletin B-0036-20 (30 Sept 2020) — insurers' use of third-party data verified

Excerpt: tx-tdi-b-0036-20 · regulatory bulletin addressed to all regulated entities and their agents (government edict) · in force from 2020-09-30

Regulated entities "are responsible for the accuracy of the data used in rating, underwriting, and claims handling", "even if the data is provided by a third party"; "TDI may pursue enforcement action against an insurer if its use of inaccurate data harms policyholders"; "Insurers are encouraged to provide policyholders with a way to review and correct data being used by the insurer." The bulletin states it does not create a new legal duty.

Point in time

Law as of: 2026-09-29
Rules version: 2026.10+c4982313
Corpus snapshot: 2026-10-30-9c5dad5a
Engine: regbench-engine/0.5.0 · deterministic-1
Fingerprint: fc824ebb189b04079f136f84 (pattern grouping, not an integrity check)
Input digest: 666caa8445ede4bd4bf9a466b2c06025816d2c16b3a876cd81d7d8c1e332321c
Evaluated: 2026-10-31 05:42:52 UTC
Exhibit C case file: yes

Ledger

Entry: #5587 · assessment · recorded 2026-09-29T16:19:06+00:00
Hash: 26de797706840c959951d2e7d6258a2f70aca817d8a6c243e4f090a2a3e82fbb
Previous: df5d74e3948a94b2b37ce8025bd41a49fabecb9850d51d1e348a77ba5e50ab92
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

Resolved by underwriter · outcome remediated · 37.2 hours after it opened · Resolved in the carrier's review queue (synthetic).

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: uw-triage v2.4 · internal · high-risk class: underwriting
Governance attested: True
Testing report: test://bluebonnet/uw-triage/2026Q3
Model documentation: doc://bluebonnet/uw-triage/2.4
Feature classes: application_data, claims_history, consumer_report, credit, geography
Protected factors used: none
External data (ECDIS): False
Consumer report / credit: True / True
Data sources: none recorded

Decision: refer · score 0.676
Human review: yes (underwriter)
Adverse to consumer: False
Notice: not recorded · reasons: False · specific: False · external data disclosed: False
Appeal channel: –
Consumer token: tok_f3d744f400