Re: Request for Information and Comment on Financial Institutions’ Use of Artificial Intelligence, Including Machine Learning
Office of the Comptroller of the Currency |
Federal Deposit insurance Corporation |
National Credit Union Administration |
Board of Governors of the Federal Reserve System |
Bureau of Consumer Financial Protection |
Re: Request for Information and Comment on Financial Institutions’ Use of Artificial Intelligence, Including Machine Learning
To the Above-Listed Agencies:
The American Bankers Association (“ABA”) welcomes the opportunity to comment on the request for information and comment (“RFI”) on financial institutions’ use of artificial intelligence (“AI”), including machine learning (“ML”), by the Board of Governors of the Federal Reserve System (“FRB”), Bureau of Consumer Financial Protection (“CFPB”), Federal Deposit Insurance Corporation (“FDIC”), National Credit Union Administration (“NCUA”), and Office of the Comptroller of the Currency (“OCC,” collectively the “Agencies”)
This RFI is a timely look at an important issue. Banks are actively evaluating ways to safely and responsibly integrate AI solutions to better serve customers and communities across the country. ABA believes AI holds tremendous opportunity to make financial services safer, more convenient, and more inclusive. This opportunity can only be realized when AI is implemented responsibly and the risks associated with AI are well managed. Fortunately, banks are moving carefully to avoid any unintended consequences and banking regulations today already capture the risks associated with AI. Regulators should focus on areas where they can provide clarity to allow banks to adopt AI and ensure that all financial services providers are held to this same high standard.Our main points with respect to the RFI, which are discussed at greater length below, are as follows:
For more, please download the full letter.