USA: EPIC comments to CFPB urge application of universal AI guidelines and OECD AI principles
The Electronic Privacy Information Center ('EPIC') announced, on 5 October 2020, that it had sent comments to the Bureau of Consumer Financial Protection ('CFPB') on its request for information on the Equal Credit Opportunity Act of 1974 and Regulation B. In particular, the comments address artificial intelligence and machine learning ('AI/ML'), and recommend that the CFPB revise its regulations and/or provide new guidance to financial institutions regarding their use of AI/ML systems in light of concerns about bias, transparency, and accountability. Specifically, the comments urge the CFPB to build upon the Universal Guidelines for Artificial Intelligence and the Organisation for Economic Co-operation and Development ('OECD') AI principles. The comments highlight that this would include transparency, assessment, and accountability for the risks posed by AI, data quality obligations, prohibiting secret profiling, as well as ensuring robustness, security, and safety throughout the AI system lifecycle.