Actuarial AI Compliance

AI for actuaries that won't
fabricate a mortality table.

ASOP No. 41 transparency. NAIC Model #672 immutable audit. ERISA §404(c) fiduciary grounding. Every assumption sourced, every methodology disclosed — or blocked before it exits the model.

ASOP No. 41 disclosure layer
NAIC Model #672 immutable audit
ERISA §404(c) fiduciary grounding
SOA mortality table verification
30-day pilot, deposit credits month 1

Built for the liability exposure
actuarial AI actually creates

A fabricated mortality table assumption or a cited SOA study that doesn't exist isn't a minor error — it misprices risk for thousands of policyholders. Every Sturna layer maps to a specific professional standard.

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ASOP No. 41 Disclosure Layer

Every actuarial assumption, methodology, and data source must be disclosed under ASOP No. 41 (Actuarial Communications). Sturna enforces this at the generation level — output without traceable sourcing is flagged or blocked. No undisclosed assumptions exit the model.

ASOP No. 41 — Actuarial Communications
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NAIC Model #672 Audit Trail

Every actuarial output — assumption sets, reserve calculations, risk model outputs — is written to an HMAC-signed append-only audit log. NAIC Model #672 requires documented actuarial review. The log satisfies that requirement by construction, not retroactive export.

NAIC Model #672 — Actuarial Opinion
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Mortality Table Verification

AI models hallucinate non-existent SOA mortality tables (VBT, CSO) and fabricate assumption rates with false precision. Sturna cross-validates every mortality table reference against the actual published SOA tables. A table reference that doesn't exist is blocked before output.

SOA 2015 VBT / 2017 CSO

ERISA §404(c) Fiduciary Grounding

For pension and retirement actuarial work, AI outputs that inform fiduciary decisions must meet ERISA §404(c) prudent expert standards. Sturna traces every claim to a verified source. Ungrounded recommendations that could influence benefit plan decisions are blocked.

ERISA §404(c) — Fiduciary Relief
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Triple-Gate Verification

Three independent verification layers run on every response: (1) completeness check — assumption set fully disclosed; (2) accuracy check — methodology and data sources verified against SOA/NAIC standards; (3) stress check — MARCH adversarial gate catches fabricated table references and methodology violations.

Systematic defense in depth

AAA & SOA Standard Compliance

The American Academy of Actuaries and Society of Actuaries publish standards of practice that govern methodology. Sturna's knowledge corpus is grounded in current ASOP, NAIC Model regulations, SOA research papers, and AAA practice guidelines — not pattern-matched generation.

AAA Code of Professional Conduct

Watch actuarial hallucination get intercepted
on real ASOP adversarial prompts

Five prompts designed to bait an ungrounded model into fabricating mortality tables, NAIC regulations, or SOA studies. Left side is live GPT-4 output. Right is Sturna. API calls are real.

Sturna Triple-Gate — Actuarial Hallucination Probe
Live API · GPT-4 vs. Sturna · ASOP No. 41 + MARCH adversarial gate
LIVE ENGINE
Running Triple-Gate verification — calling live API…
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Select a prompt to run live against GPT-4 vs. Sturna.
Real API calls — ~2–4s response time.

Every gate runs on every response.
Every failure is logged.

Three independent verification layers operating simultaneously — not sequentially. Any single gate failure blocks the output and writes an audit entry. There is no pass-if-two-of-three.

G1

Completeness Check

Verifies the actuarial response is complete: assumption set fully disclosed per ASOP No. 41, all data sources named, no silent extrapolations. Partial responses with undisclosed methodology gaps are flagged before output.

Artifact: ASOP No. 41 disclosure checklist — field-level completeness verification
Artifact: Assumption audit log entry — hash-linked to output record
Latency budget: ≤800ms (non-blocking in parallel gate execution)
✓ Completeness & Disclosure Pass
G2

Accuracy & Quality Check

Validates methodology and citations against the SOA/NAIC published corpus. Mortality table references are looked up against actual VBT/CSO tables. ASOP citations are verified against published standards. Any reference that doesn't exist is blocked.

Artifact: Citation map — each table/standard reference → verified source hash
Artifact: SOA/NAIC corpus cross-check — relevance score per citation (≥0.85 required)
Latency budget: ≤1,400ms (parallel to G1 and G3)
✓ Accuracy & Citation Verified
G3

Stress & Real-World Check

MARCH adversarial gate — a second agent with information asymmetry reviews the output independently. It checks for plausible-sounding but non-existent standards (NAIC Model #847, SOA 2022 Enhanced VBT), fabricated q-values, and ERISA fiduciary exposure from AI-assisted benefit determinations.

Artifact: MARCH checker trace — adversarial agent independent verdict
Artifact: Hallucination verdict: PASS / WARN / HALLUCINATION_DETECTED
Latency budget: ≤2,100ms (longest gate, hard constraint)
✓ MARCH Adversarial Pass

Every standard verified real. No fabricated rule numbers.

ASOP No. 41
Actuarial Communications
Requires actuaries to clearly identify assumptions, methods, and data sources in all communications — including AI-generated outputs they sign off on.
ASOP No. 25
Credibility Procedures
Governs when actuaries may blend external data into credibility-weighted assumptions. AI that bypasses credibility testing violates this standard.
NAIC Model #672
Actuarial Opinion & Memorandum
Requires a documented actuarial review of all life insurance reserve calculations. AI-generated reserve outputs without HMAC-linked review evidence are non-compliant.
SOA 2015 VBT
Valuation Basic Table
The Society of Actuaries Valuation Basic Table is the primary mortality reference for U.S. life insurance. AI must cite this — not invented table variants.
ERISA §404(c)
Fiduciary Relief
Plan fiduciaries can reduce liability if participants make informed investment decisions. AI-assisted benefit analysis that influences those decisions must meet the prudent expert standard.
AAA Code §7
Actuarial Communications Obligation
An actuarial statement must clearly indicate whether AI tools were material to the work product. An actuary cannot delegate disclosure obligations to the AI system itself.
30-Day Actuarial AI Pilot

Reserve your dedicated actuarial agent pool now.

The next ASOP enforcement action won't cite your firm. Sturna deploys an actuarial-tuned agent pool with verified methodology grounding, NAIC Model #672 compliant audit trail, and ASOP No. 41 disclosure enforcement — active from day 1. Deposit credits your first month. No lock-in.

  • Dedicated actuarial-tuned agent pool (isolated tenancy)
  • ASOP No. 41 disclosure layer — every assumption sourced
  • NAIC Model #672 HMAC-signed audit trail from day 1
  • SOA mortality table verification (VBT, CSO cross-check)
  • ERISA §404(c) grounding for pension/benefit plan work
  • Triple-Gate verification on every actuarial response
  • AAA/SOA standard alignment documentation
  • Convert or get pro-rated refund at day 30
$2,500
one-time pilot deposit
✓ Credits your first month of service
🔒 Payments secured by Stripe
Pro-rated refund if pilot doesn't deliver
No annual contract required
NAIC Model #672 audit trail active from day 1

Common questions from Chief Actuaries and DCIAs

What does ASOP No. 41 actually require for AI-generated actuarial work?
ASOP No. 41 (Actuarial Communications) requires that actuarial communications clearly identify the actuary responsible, the assumptions and methodology used, and any significant sources of uncertainty. When AI generates actuarial estimates, the actuary who signs off remains responsible for ensuring the AI's assumptions, data sources, and methodology meet ASOP standards. Sturna's disclosure layer enforces this at generation time — every AI output includes an assumption source map traceable to verified data.
How does Sturna verify mortality table references?
Sturna's Gate 2 (Accuracy Check) cross-validates every mortality table reference against the published SOA corpus — including the 2015 Valuation Basic Table (VBT), 2017 Commissioners Standard Ordinary (CSO), and historical tables. If an AI model cites a non-existent table (e.g., "SOA 2022 Enhanced VBT" — which does not exist) or fabricates q-values, Gate 2 blocks the output before it exits. The block is logged to the NAIC Model #672 audit trail.
What's the ERISA §404(c) exposure when AI contributes to benefit plan decisions?
ERISA §404(c) allows plan fiduciaries to reduce liability when participants make informed, voluntary investment decisions. If AI-assisted actuarial analysis informs the investment menu or contribution modeling, and that analysis contains fabricated assumptions, the fiduciary cannot rely on §404(c) protection. Sturna's grounding layer traces every claim supporting a benefit plan recommendation to a verified source — ungrounded claims are blocked, protecting the fiduciary record.
Is the $2,500 deposit refundable?
Yes. If at day 30 the pilot hasn't demonstrably reduced hallucination exposure or improved actuarial workflow compliance, you receive a pro-rated refund of unused days. The deposit is not speculative — it converts to month 1 of service upon kickoff.
How does the NAIC Model #672 audit trail work in practice?
Every actuarial output — assumption set, reserve calculation, risk model response — is written to an append-only log at creation time. Each entry is signed with HMAC-SHA256 using the previous entry's hash, forming a cryptographic chain. Any tampering invalidates downstream entries. The log is available for regulatory examination without reconstruction. For state insurance department reviews requiring NAIC Model #672 actuarial opinion documentation, the log satisfies the underlying audit requirement.
What AAA Code of Professional Conduct obligations apply to AI-assisted actuarial work?
Precept 7 of the AAA Code requires that actuarial communications not be misleading. An actuary who presents AI-generated output as their own work product without verifying the assumptions and methodology could violate Precept 7. Precept 3 requires maintaining competence — which now includes understanding the limitations of AI tools. Sturna provides the verification infrastructure that enables the actuary to satisfy these obligations: every assumption sourced, every table verified, every output ASOP-auditable.