July 21, 2021

Request for Information on Use of Artificial Intelligence Extended

By Andrew Jagelski, Staff Accountant, Assurance Services

Request for Information on Use of Artificial Intelligence Extended Intelligent Automation

Artificial Intelligence (“AI”) is a developing technology offering significant benefits to most financial institutions that have the potential to improve efficiency, enhance performance, and reduce overhead costs. Financial institutions are in the process of exploring AI-based applications in a variety of areas such as flagging, unusual transactions, personalization of customer services, credit decisions, risk management, textual analysis and cybersecurity. As with all developing technologies, however, integrating AI-based applications comes with risks. The vulnerability of AI operations could potentially affect an institution’s safety and soundness.

With these benefits and risks in mind, on March 31 the Board of Governors of the Federal Reserve System, the Bureau of Consumer Financial Protection, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of the Comptroller of the Currency (collectively, “the Agencies”) published in the Federal Register entitled “Request for Information and Comment on Financial Institutions’ Use of Artificial Intelligence, Including Machine Learning” (“the RFI”). The RFI invited financial institutions to submit comments on the use of AI by June 1, 2021.

As the June 1 deadline approached, the Agencies conferred to consider numerous requests for additional time received from financial institutions still in the process of exploring the uses of artificial intelligence-based applications. The institutions stressed that significant coordination was necessary to compile adequate details to comprehensively respond to the RFI.

In May 2021, the Agencies agreed to extend the deadline for comments to July 1, 2021. At Marcum, we have a dedicated team exploring ways that AI can add value to our service offerings and improve our efficiency. Financial institutions stand to benefit from this developing technology and should continue to monitor the Agencies’ guidance on acceptable uses of AI. Insert Marcum conclusion/observation here. For additional information, please contact Marcum’s Financial Institution Industries Service Group.