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NAFCU responds to OMB memo on AI
NAFCU Senior Counsel for Research and Policy Andrew Morris wrote to the Office of Management and Budget (OMB) in response to its memo on governance, innovation, and risk management for regulatory agencies opting using artificial intelligence (AI).
In the letter, Morris explained that federal banking regulators, like the CFPB, have less guardrails for AI use than credit unions do. He expressed NAFCU’s support for the memo’s instruction, which directed agencies to “annually submit an inventory of its AI use cases to OMB and subsequently post a public version on the agency’s website.”
Additionally, Morris called on OMB to solicit public comment “on any supplemental instructions for preparing an agency’s AI use-case inventory.” He also requested OMB add another category in the memo to cover “the use of AI by a financial regulatory agency for the purpose of making any material decision related to the supervision of a financial institution.” He noted its unclear whether the CFPB is using AI for those purposes, but added “it is likely the CFPB is one covered agency using AI as part of its supervisory prioritization process.”
Morris concluded by recommending OMB tailor its memo further to promote AI transparency from federal financial regulators. Read the full letter.
NAFCU wrote to the CFPB in October to request the agency be more transparent about its AI usage. The association will continue to call on federal financial regulators to be fully transparent.