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American Financial Services Association

AFSA Comments on AI / ML

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AFSA Comments on AI / ML

The American Financial Services Association (AFSA) today submitted a comment letter in response to a Request for Information (RFI) from several federal agencies on financial institutions’ (FIs’) use of artificial intelligence (AI), including machine learning (ML).
 
“AFSA believes that AI and ML can help expand access to responsible credit while at the same time satisfying the principles of anti-discrimination, accuracy, and education under the ECOA and its implementing regulation (Regulation B),” the comment letter noted.
 

In the RFI, the agencies sought information on FIs’ risk management practices related to the use of AI, barriers or challenges when developing AI, and benefits to financial institutions and their customers from its use. The agencies requested input from all relevant stakeholders to see if any clarification would be helpful from the agencies to FIs to ensure AI is used in a safe and sound manner and in compliance with applicable laws and regulations.

In the letter, AFSA also outlined ways in which FIs identify and manage risks related to the “explainability” of AI and how FIs adhere to certain statistical sound development standards and practices to ensure its predictability and avoid overfitting. In addition, AFSA explained how FIs use various techniques to evaluate the compliance of AI-based credit determination approaches.

July 1st, 2021 by