XBRL US submitted a comment letter in response to the Request for Information and Comment on Financial Institutions’ Use of Artificial Intelligence, including Machine Learning. The Request was published by five federal agencies: the Office of the Comptroller of the Currency, the Bureau of Consumer Financial Protection, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the National Credit Union Administration.
While the Request for Information focuses on financial institution use of AI platforms, we used our comment letter as an opportunity to point out that regulators should also consider how financial data that the regulator collects from these institutions is used. Each of the five federal agencies that is part of this Request collects financial data from multiple financial institutions. Data aggregators, analytics providers, and services offering AI platforms access the data provided by these regulators. In our letter, we urged the regulators to ensure that the data they collect from financial institutions is equally available to all users, of high quality, and available in structured, standardized format. Providing financial institution data in machine-readable, structured format will ensure that it is easier and less expensive to analyze; and that AI platforms that leverage it, produce better, more reliable outcomes not just for regulators but for the public as well.