WASHINGTON—The CFPB needs to be more transparent when it comes to how it might use artificial intelligence (AI) and machine learning (ML) in its future supervision, according to a new letter from NAFCU to the Bureau.
In the letter, NAFCU Senior Counsel for Research and Policy Andrew Morris noted the CFPB has indicated an intent to leverage AI within the supervisory prioritization process, but said it has also failed to provide information about its specific use.
Morris said the lack of an explanation related AI or ML 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.”
What Vendor Contracts Indicate
“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 stated the CFPB’s contracting for data analytics does not typically reveal whether awards encompass potential use of AI, and he further 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.”
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