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CR response to the Office of the Comptroller of the Currency (OCC) advanced notice of proposed rulemaking on Digital Activities.

If regulators fail to enact sufficient safeguards around the use of algorithms, artificial intelligence and machine learning, the risk is that these systems will perpetuate and further entrench existing inequities and biases.

With the rise of digital finance comes additional consumer risks. The privacy harms of data collection, and the potential discriminatory effects of algorithmic decision making are urgently in  need of attention from federal financial regulators. In comments to the OCC, CR urges the Office to redouble its efforts to ensure consumer financial data privacy, enhance its scrutiny of artificial intelligence and machine learning in financial services with an aim to prevent  discrimination and bias, and to ensure other consumer protections.