Industries / Insurance
Answers an examiner can follow.
You answer to state insurance departments. Any DoI request supported. Every answer your AI gives names the approved source behind it, and who signed it.
Without Cognatum
Which version did we recommend?
“I need the answer fast, but I also need to know I am allowed to say it.”
Before an assistant answers a producer or a service rep, somebody has to say which wording it may use, and where that wording came from.
Your producers sell across many states, and the filed wording is not the same in all of them.
An examiner asks what was recommended, on what basis, and what the customer was told at the time.
A form is refiled in one state and the old wording carries on being quoted in the others, because nothing knows which answers depend on it, and an answer assembled from files that have since changed cannot be rebuilt.
Yes. It is available on all issue ages and the filed wording is the same across states.
No source · no approver · no date
Why this industry
What the examiners actually ask.
Three things decide whether an assistant reaches production at a carrier. Each one turns on whether the record behind the answer still exists.
- Suitability and best interest. A recommendation rests on a stated basis, recorded when it is made. An answer that cannot say which guidance it used cannot support one. Here every answer comes from a numbered version.
- Filed wording. Forms, endorsements and sales material are approved as filed. A language model rephrases by default, which turns approved wording into new wording. Approval happens once, before use, and the assistant serves only what passed it.
- Records and data security. Your information security program has to be written down, and what you did has to be evidenced afterwards. A live index of everything the carrier has ever written is not a bounded input. A set of approved, numbered entries is.
What we will not claim
None of this makes your company compliant with state insurance law or with any model regulation, and we will not tell you it does. Examinations assess companies, not software.
What Cognatum supplies is evidence toward duties your company already carries: the named approver, the date, the version history, and the source behind every answer the AI serves.
Which retention period applies to client trade communications?
Entry SOP-4471
- v4 In force
Retention extended to seven years for client trade communications.
D. Whitfield, Records management · 2026-07-02
- v3 Superseded · retained
Chat channels brought into scope.
D. Whitfield, Records management · 2025-11-14
- v2 Superseded · retained
Exception process added for legal hold.
M. Alvarez, Compliance · 2025-03-09
- v1 Superseded · retained
First approved version.
M. Alvarez, Compliance · 2024-06-18
→ what the entry said on a date is a lookup
With Cognatum
Five things that need approving.
What an assistant answers from at a carrier is not one kind of thing. Five classes carry an approval duty of their own.
Suitability
The basis, recorded once
A recommendation rests on a stated basis. The entry carries the current guidance, its approver, and the date it took effect.
Filed wording
Forms and endorsements
Filed language is approved as filed. The wording comes back exactly, from the revision in force in that state.
Sales material
What a producer may say
A producer quoting the assistant is quoting the carrier. Approved sales language is served as written, never summarised.
Claims
The procedure in force
Ask how a claim is handled and the answer comes from the revision in force, with a named approver on it.
Underwriting
What may be written, and where
Appetite and eligibility change by state and by quarter. Approve the change and the old entry is archived with the dates it applied.
Why not search
Search cannot show a basis.
An index can find the guidance document. It cannot say which version was in force when the recommendation was made.
Search points at a file wherever it sits. It can rank that file. It cannot number it, approve it, or record who stood behind it.
A system of record stores the approved answer itself, so the version, the approver and the effective date belong to the answer and travel with it.
That is why an examination question has an answer here.
Returned word for word
“Guarantees are backed by the claims-paying ability of the issuing insurance company. This product is not a deposit and is not insured by any federal government agency.”
D-318 · v2
- Producer portal Unchanged
- Illustration footer Unchanged
- AI assistant Refused
What was refused
Asked to send “is not a bank product” in place of “is not a deposit and is not insured”. Rewording approved text is refused, not corrected.
Frameworks
What each framework asks.
| Instrument | What it asks of you | What we supply toward it |
|---|---|---|
| NAIC Suitability in Annuity Transactions Model Regulation (#275) | That a recommendation rests on a documented basis, recorded at the time it is made. | Each entry carries the guidance it came from, its approver and its effective date, so the basis behind an answer is a lookup rather than a reconstruction. |
| NAIC Advertisements of Life Insurance and Annuities Model Regulation (#570) | That what is said to a consumer is truthful and matches the material that was approved for use. | Approved wording is returned word for word rather than paraphrased, so filed language cannot drift in the retelling. |
| NAIC Insurance Data Security Model Law (#668) | A written information security program, with events investigated and reported to the commissioner. | Access to an entry is decided by clearance at the AI layer, and every refusal is recorded with who asked and when. |
| State records retention requirements | That records are kept for a set period and produced on examination. | Every superseded version is retained with the dates it applied, so producing what was live on a given date is a query. |
| Market conduct examination | That your practices can be evidenced afterwards rather than described from memory. | The approval trail is kept per entry and per version, so a period is evidenced from the record instead of being assembled before the visit. |
This table describes obligations that fall on your organization, and the evidence Cognatum produces toward them. It is not a claim of certification or conformity, ours or yours.
In practice
Which wording applies in that state?
A service team is asked what a policy covers, and the filed wording differs across the states the carrier writes in.
They ask, and the answer comes from the revision in force for that state, with the approver and the effective date attached.
Where two approved sources disagree, neither is served as approved. Where a date settles it, the resolution is drafted and queued for approval. Only a real disagreement goes to a named person to settle.
Before the next examination, compliance reads the usage record rather than assembling evidence from scratch.
Source A · Retention policy v7
Supervisory records are kept for six years.
Source B · Supervisory procedures v3
Supervisory records are kept for five years.
Neither is served as approved
The record settles it
Resolution queued for approval
Entry B supersedes A · Effective 2026-05-01 · queued
A real disagreement
Flag open
Routed to a named person · Records management
Common questions
What carriers ask first.
What do we show an examiner who asks about the AI answers our people gave?
The record. Every entry the assistant answers from carries a named approver, an approval date, a version history, and the source it came from. You produce the entry, who approved it, when it changed, and what it said on any given date. How that fits your compliance program is a decision for compliance and counsel.
Our filed wording differs by state. How does the assistant keep them apart?
Each filed form becomes a numbered entry with one revision in force per state and a named approver on every change. Ask a coverage question and the answer comes from the revision that applies, cites it, and stops being served the moment a new one is approved.
Does this satisfy our suitability obligations?
No, and we do not claim it does. A recommendation is made by a person and assessed as your practice, not as a feature of a product. What you get is the record behind it: the guidance the answer came from, who approved that guidance, and the date it took effect.
How does this sit with our information security program?
Clearance is decided at the point the answer is made, not only at the document store. Two people can ask the same question and get different answers, or none. Denials are recorded with who asked and when, so a refusal is explainable rather than mysterious.
Rates and appetite changed mid-quarter. How does the wrong answer stop?
The moment the new entry is approved it is what the assistant serves, on every channel at once. The old version is archived rather than deleted, with the dates it applied. An index waits for somebody to find and fix every stale copy.
Who holds the approval, compliance or the business?
Your company decides, per type of entry. What does not vary is the mechanism: every approval is a named person and a date, and the assistant serves nothing that has not passed one.
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