Ensuring “automated systems” development and use is consistent with federal laws
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April 2023
The Consumer Financial Protection Bureau (CFPB), the Department of Justice Civil Rights Division (DOJ), the Equal Employment Opportunity Commission (EEOC), and the Federal Trade Commission (FTC) jointly release an Interagency Statement reiterating their “resolve to monitor the development and use of automated systems” and to “vigorously use their collective authorities to protect individuals’ rights regardless of whether legal violations occur through traditional means or advanced technologies.”
In particular, the agencies:
Each of the agencies has previously expressed concerns about, and/or taken actions to address, potentially harmful uses of “automated systems”; a representative list is included as part of the Interagency Statement.
In separate but related statements, the agencies each reinforce their intention to use their enforcement and/or supervisory authorities:
The CFPB also indicates it will be i) proposing rules related to bias and discrimination in home valuations to “make sure artificial intelligence and automated valuation models have basic safeguards when it comes to discrimination;” and ii) releasing a white paper “discussing the current chatbot market and the technology’s limitations, its integration by financial institutions, and the ways the CFPB is already seeing chatbots interfere with consumers’ ability to interact with financial institutions.”
Enforcement/Supervision to “Automated Systems”
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