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CR’s Comment on Financial Institutions’ Use of Artificial Intelligence/Machine Learning for Federal Financial Regulatory Agencies

Consumer Reports (CR) submitted comments to five federal financial regulatory agencies that are gathering insights on financial institutions’ use of artificial intelligence. They are seeking information on how financial institutions use AI in their activities, including fraud prevention, personalization of customer services, credit underwriting, and other operations. Our comment includes the ways financial companies are using AI as well as policy recommendations for how agencies should think about regulating these emerging technologies. CR recommends the following:

  • The use of algorithms should be transparent to the end users.
  • Algorithmic decision-making should be testable for errors and bias.
  • Algorithms should be designed with fairness and accuracy in mind.
  • The data set used for algorithmic decision-making should avoid the use of proxies for prohibited factors.
  • Algorithmic decision-making processes that could have significant consumer consequences should be explainable.
  • If the use of AI or algorithms in financial services leads to less fair or inclusive outcomes, it should not be used.

Please see the attached PDF for the full comment.