US Agencies – Seek a wide range of views on financial institutions’ use of Artificial Intelligence (AI) and Machine Learning (ML)

March 29, 2021 – Agencies issued requests for information (RFI), to understand the broadening use of AI and ML, in activities related to fraud prevention, customer service, and underwriting. To discern challenges in development, adoption, and management. Also firms’ governance, risk management practices, and internal controls for sound use of AI/ML.

Overview of Request
Request articulates the Agencies’ support for responsible innovation, which includes the use of AI/ML across the spectrum of cybersecurity, compliance, institutional, and retail use.

Notes that such applications may also create potential risks or by-products, such as unlawful discrimination, operational vulnerability, third-party risk, and model risk. Such risks may infringe upon abusive practice protections under the FTC act, (15 USC 45), as well as unfair, deceptive, and abusive acts under the Dodd-Frank Act, (12 USC 5531). In addition, RFI underscores the critical role of data and its correct usage in AI/ML.

Solicitation of Specific Feedback
RFI seeks input from financial institutions, trade associations, and consumer groups. Questions provided on conceptual soundness, data processing and usage, algorithmic overfitting, cybersecurity risk, dynamic updating by AI training data, third party risk, fair lending, and particular risks faced by community institutions.

Consultation Deadline
Comments due by June 1, 2021.

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