On January 14, Michigan’s Department of Insurance and Financial Services (DIFS) issued a bulletin reminding all financial service providers regulated by DIFS that decisions and actions made using advanced analytical and computational technologies, including AI systems, that may impact consumers must comply with all laws and regulations. The bulletin set forth DIFS’ expectations for governing the development, acquisition and use of AI technologies, and advised financial service providers which information and documentation may be requested during investigations or examinations. DIFS recognized a report issued by the Treasury in December 2024 (“Artificial Intelligence in Financial Services”) as an appropriate source of guidance for financial service providers developing and using AI systems.

The bulletin highlighted that AI and its systems can present risk, including inaccuracy, unfair discrimination, data vulnerability, lack of transparency, and inability to map decision processes, and stated that financial service providers should take steps to mitigate these risks. DIFS stated that decisions made using AI systems must comply with existing risk and management standards and encouraged the use of verification methods to identify errors and biases in models and systems. All financial service providers are expected to develop, implement and maintain a written AI systems program for the responsible use of AI systems, and those not formally engaging in AI systems should establish employee acceptable use policies.