Joint Comment Letter re Request for Extention RFI on Financial Institution's Use of AI

Ladies and Gentlemen:

The undersigned financial services trades respectfully request that the Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, Bureau of Consumer Financial Protection and National Credit Union Administration (collectively the “Agencies”) extend by thirty days the deadline for comments on the request for information on financial institutions’ use of artificial intelligence (AI), including machine learning (ML). 

We support the Agencies’ efforts to gain more information on the use of AI in financial services, including how financial institutions ensure the quality of AI outputs and manage model risk. The financial services sector is strongly committed to promoting the responsible use of AI and transparency in decision making, given the potential long-term benefits that AI may provide consumers and the future of financial products. We are actively engaged in a careful review and analysis of the questions posed in the RFI in order to develop robust comment letters on behalf of our members that meaningfully respond to the Agencies’ questions regarding financial institutions’ use and management of AI.

In light of the significance of the topic and the complex technical nature of the information requested, we are concerned that the existing comment deadline will not provide us with sufficient time to perform the level of analysis that this RFI warrants. As noted in the RFI, financial institutions are exploring the use of AI-based applications in a variety of fields, involving different business units across each organization. To that end, significant coordination is necessary within financial institutions to compile adequate details to comprehensively respond to the questions posed by the Agencies. For these reasons, we respectfully request that the Agencies extend the deadline for comments on the RFI for an additional thirty days. Our goal is to develop carefully considered and well-informed comment letters that will be constructive to the Agencies’ future efforts on AI, and we believe this additional time is necessary in order us to achieve that goal.

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If you have any questions, please contact Matthew Daigler at (202) 663-5130 (mdaigler@aba.com), Stephanie Wake at (202) 589-2432 (stephanie.wake@bpi.com), Andre’ Cotten at (202)552-6360 (acotten@consumerbankers.com), Michael Marshall at (202) 821-4411(michael.marshall@icba.org), Stephanie Webster at (646) 213-1149 (swebster@iib.org) or MelissaMacGregor at (202) 962-7300 (mmacgregor@sifma.org).

Respectfully submitted,

 

Matthew Daigler
Vice President/Senior Counsel, Innovation Policy and Regulation
American Bankers Association

Stephanie Wake
Vice President, BITS
Bank Policy Institute

Andre’ B. Cotten
Assistant Vice President, Regulatory Counsel
Consumer Bankers Association

Michael Marshall
Director, Regulatory Legal Affairs
Independent Community Bankers of America

Stephanie Webster
General Counsel
Institute of International Bankers

Melissa MacGregor
Managing Director & Associate General Counsel
Securities Industry and Financial Markets Association