Selected U.Privacy and Cyber Updates. On January 17, 2024, the New York State Department of Financial Services (NYDFS) issued a proposed circular letter for comment, Use of Artificial Intelligence Systems and External Consumer Data and Information Sources in Insurance Underwriting and Pricing. The letter details the NYDFS's expectations and guidelines for the use of artificial intelligence systems (AIS) and external consumer data and information sources (ECDIS) by "all insurers authorized to write insurance in New York State, licensed fraternal benefit societies, and the New York State Insurance Fund." While the NYDFS notes that AIS and ECDIS can provide certain benefits to consumers and insurers, they flag the unique risks - "the self-learning behavior of AIS increases the risks of inaccurate, arbitrary, capricious, or unfairly discriminatory outcomes," and that those outcomes can disproportionately affect marginalized or vulnerable communities and individuals.