The RFI asks for stakeholders to provide information on “potential opportunities and risks related to the use of AI in financial services.”6 Throughout our report and in response to this RFI, we highlight potential risks associated with the use of AI in the financial sector, including but not limited to:7 Prevention of access to financial services: AI-powered systems may prevent consumers from acc. [...] Specifically, in this report, these agencies include the Treasury Department, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Commodity Futures Trading Commission, the National Credit Union Administration, the Securities and Exchange Commission (SEC), the Consumer Financial Protection Bureau, the Fi. [...] The definition of “automated systems” is used in the AI Bill of Rights in conjunction with a two-part test to help determine the appropriate scope, including the critical impact of the use of the AI or automated system. [...] Question 6 Question 6: To what extent are a particular financial institution's AI models and tools connected to other financial institutions' models and tools? What are the benefits and risks to financial institutions and consumers when the AI models and tools are interconnected among financial institutions?”14 The concentration of advanced foundation models and commercial cloud computing in a han. [...] ● Under the Gramm-Leach-Bliley Act, we propose that the Office of the Comptroller of the Currency and the other relevant agencies: ○ Require third-party AI audits for all institutions; ○ Require red-teaming of AI for the largest institutions; and ○ Require disclosure of annual resources on AI cybersecurity and AI risk management and compliance.
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- United States of America
Table of Contents
- RE Request for Information on Uses Opportunities and Risks of Artificial Intelligence in the Financial Services Sector 89 FR 50048 1
- Introduction 2
- Customers 2
- Banks Securities brokers and futures commission merchants securities and derivatives exchanges and other market intermediaries 3
- Prevention of access to financial services Algorithmic discrimination that may exacerbate historical inequalities AI-enabled fraud Failure to comply with anti-money laundering requirements 3
- Threats to safe secure and stable financial systems 4
- Question 1 4
- Question 6 5
- Dodd-Frank Act 6
- Ensure firms may move between different AI systems before they contract for one system. 6
- Question 11 6
- Question 18 7
- Minimum risk management practices 7
- AI audits 7
- Ensuring explainability and legibility 7
- AI red-teaming 8
- Disclosure of annual resources spent on AI cybersecurity and AI risk management and 8
- Where relevant providing for human review of AI-influenced determinations 8
- Where possible ensuring firms can move between different AI systems 8
- Summarizing report proposals 9
- Bank Secrecy Act 9
- Gramm-Leach-Bliley Act 9
- Community Reinvestment Act 9
- Federal Deposit Insurance Act Federal Credit Union Act and the Bank Holding 9
- Company Act 9
- Dodd-Frank Act 10
- Equal Credit Opportunity Act 10
- Fair Credit Reporting Act 10
- Consumer Financial Protection Act 10
- Securities Exchange Act of 1934 11
- Investment Advisers Act of 1940 11
- Commodity Exchange Act 11
- Conclusion 12
