Oct 2023: Comment on Colorado’s Quantitative Testing Protocol

In October 2023, Bell Analytics submitted an informal comment on the Colorado Division of Insurance’s DRAFT PROPOSED Algorithm and Predictive Model Quantitative Testing Regulation, regarding unfair discrimination testing of life insurance underwriting and pricing models using external consumer data. 

Our comments reflected an initial, high level analysis of the testing protocol, which we followed up with more in-depth analysis via a real-world case study. 

In the document, we:

• Identified several ambiguous aspects of the protocol

• Raised concerns regarding (1) the potential to conflate impact of external consumer data with traditional underwriting factors in some of the tests as well as (2) technical issues with interpretability and the use of linear/logistic regression to assess alternative classes of models

• Suggested alternative approaches based on best practice in consumer lending

Find our full comment here.