Image created in Midjourney

Image created in Midjourney

Image created in Midjourney

ECDIS, Regulation, Public Comment

Dec 2023: Colorado’s Quantitative Testing Protocol with Real World Data

Case study on Colorado’s draft protocol for testing unfair discrimination showcases challenges devising globally-applicable approach.

Elaine Gibbs, March 13, 2024

In response to Colorado Division of Insurance’s DRAFT PROPOSED Algorithm and Predictive Model Quantitative Testing Regulation, released in October 2023, Bell Analytics conducted a case study, applying the draft protocol to real-world data. 

First, we inferred racial and ethnic classifications using BIFSG and compared to self-reported identifications, examining the applicability of the BIFSG approach.

We then followed the draft protocol. For certain model types and datasets, we found the test procedure:

  • May miss clear examples of illegal and unfair discrimination

  • May flag certain data points for remediation, without flagging others that are very closely related

  • Does not fully account for reasonable correlations to the underlying insurance practice

  • Omits an explicit measure of impact on protected classes or business objective specific to the data point in question

Find the full analysis here.

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