On June 6, the U.S. Department of the Treasury (Treasury) issued a request for information (RFI) seeking public input on the uses, opportunities, and risks presented by the use of artificial intelligence (AI) within the financial sector. Notably, the Treasury’s RFI comes three years after the issuance of a similar RFI by the federal banking agencies (Office of the Comptroller of the Currency, Federal Reserve Board, Federal Deposit Insurance Corporation), Consumer Financial Protection Bureau, and National Credit Union Administration on financial institutions’ use of AI, discussed here.
The Treasury’s RFI was issued the same day the Financial Stability Oversight Council and Brookings Institution launched a two-day conference to discuss the evolving role of AI in the financial system and the potential implications for U.S. financial stability. In opening remarks at the conference, Treasury Secretary Janet Yellen said federal regulators are not “seeking to reinvent the wheel” when addressing AI risks. However, she noted the rapidly evolving field of AI, and that Treasury is “pursuing a variety of initiatives to identify and address emerging risks.”
According to the RFI, the use of AI is rapidly evolving and the Treasury is committed to monitoring technological developments and their potential impact in financial services. The Treasury is interested in understanding the evolving use of AI in financial services, particularly how financial institutions are using or exploring the use of AI in the provision of products and services, risk management, capital markets, internal operations, customer services, regulatory compliance, and marketing.
The request also seeks input on the potential benefits and challenges of financial institutions’ use of AI for impacted entities. Echoing the theme of the regulatory agencies, the Treasury is particularly interested in perspectives on bias and potential discrimination as well as privacy risks, and the extent to which impacted entities are protected from and informed about the potential harms from financial institutions’ use of AI in financial services.
Toward that end, the Treasury has posed a series of questions geared toward a broad set of stakeholders in financial services (including financial product/service providers, consumer and small business advocates, academics, and nonprofits) to gather information on a wide range of topics, including:
- The types of AI models and tools that financial institutions are using;
- The actual and expected benefits from the use of AI to various stakeholders;
- The challenges or barriers to access for small financial institutions seeking to use AI;
- The risks and harms to impacted entities in using emerging AI technologies;
- The use of third-party AI providers and the management of third-party risks;
- How financial institutions are addressing any increase in fair lending and other consumer-related risks, including identifying possible discrimination related to the use of AI;
- The application of operational risk management frameworks to the use of AI; and
- The actions necessary to promote responsible innovation and competition with respect to the use of AI in financial services.
The Treasury is accepting written comments and information on these and other questions outlined in the request for 60 days following publication of the RFI in the Federal Register.
