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NAFCU calls on CFPB to be transparent about AI usage
NAFCU Senior Counsel for Research and Policy Andrew Morris wrote to CFPB Director Rohit Chopra calling on the bureau to be more transparent about potential supervisory use of artificial intelligence (AI) and machine learning (ML). Morris highlighted that the CFPB has revealed an intent to leverage AI within the supervisory prioritization process but has failed to provide information about its specific use.
Morris remarked that Chopra has discussed how lack of AI or ML explainability can lead to unfairness, and while the CFPB has focused on AI’s impact on consumers, “it is equally important that regulatory use of AI and ML follow similar standards of transparency and accountability.”
“Some important information regarding AI/ML projects comes not from the CFPB itself, but from vendors selected to perform data analysis contracts,” wrote Morris. “For example, a press release from one company describes a ‘Data Analytics Blank Purchase Agreement’ covering ‘machine learning, and natural language processing support.’ However, the CFPB has never disclosed where ML or natural language processing support may be applied.”
Additionally, Morris noted the CFPB’s contracting for data analytics does not typically reveal whether awards encompass potential use of AI. He also called on the bureau to disclose “all AI/ML applications, services, and contracts that might bear upon the agency’s supervisory work or rulemaking activity.”
Morris concluded by expressing NAFCU’s appreciation for the bureau’s “interest in ensuring that use of AI and ML meets standards for fairness and transparency,” but called on the bureau to meet its own expectations in its use of AI.