Comment on Financial Institutions’ Use of Artificial Intelligence, including Machine Learning

12 Pages Posted: 15 Jun 2021 Last revised: 10 Jan 2022

Date Written: June 1, 2021

Abstract

These Comments, submitted in response to the Consumer Financial Protection Bureau's Request for Information: Financial Institutions' Use of Artificial Intelligence, including Machine Learning, explain:

(1) how and why financial institutions' use of Artificial Intelligence/Machine Learning (AI/ML) systems to produce and micro-target digital marketing and online sales processes will lead to deception, unfair treatment, and abuse of consumers,

(2) why current approaches to financial institution supervision and enforcement can be stymied by these uses of AI/ML systems,

(3) the risks to financial institutions of relying on AI/ML systems produced by third parties to design and micro-target digital marketing and online sales processes,

(4) the risk that financial institutions' AI/ML digital marketing and online sales systems will target protected classes of consumers for deception, unfair treatment, and abuse, and

(5) some suggestions for addressing these problems.

Keywords: artificial intelligence, machine learning, financial institutions, consumer protection, discrimination, marketing, consumer law enforcement, financial institution supervision

JEL Classification: G28, O33, O38

Suggested Citation

Willis, Lauren E., Comment on Financial Institutions’ Use of Artificial Intelligence, including Machine Learning (June 1, 2021). Loyola Law School, Los Angeles Legal Studies Research Paper No. 2021-12, Available at SSRN: https://ssrn.com/abstract=3865352

Lauren E. Willis (Contact Author)

Loyola Law School Los Angeles ( email )

919 Albany Street
Los Angeles, CA 90015-1211
United States
213-736-1086 (Phone)
213-380-3769 (Fax)

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