OMB Offered Recommendations by NAFCU on Use of AI

WASHINGTON— Federal banking regulators such as the CFPB have fewer guardrails in place for the use of AI than credit unions do, according to a letter sent by NAFCU to the Office of Management and Budget.

In the letter, NAFCU Senior Counsel for Research and Policy Andrew Morris, writing in response to a memo from the OMB, expressed NAFCU’s support for the memo that directed agencies to “annually submit an inventory of its AI use cases to OMB and subsequently post a public version on the agency’s website.”

Additional Recommendations

In addition:

  • NAFCU called on OMB to solicit public comment “on any supplemental instructions for preparing an agency’s AI use-case inventory.”
  • NAFCU requested OMB add another category in the memo to cover “the use of AI by a financial regulatory agency for the purpose of making any material decision related to the supervision of a financial institution.”
  • NAFCU said it’s unclear whether the CFPB is using AI for those purposes, but added “it is likely the CFPB is one covered agency using AI as part of its supervisory prioritization process.”

NAFCU urged the OMB to tailor its memo further to promote AI transparency from federal financial regulators.

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Copyright Year: 2026
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