In comments to the Consumer Financial Protection Bureau, EPIC urged the agency to issue regulations that ensure borrowers are protected under the Equal Credit Opportunity Act and Regulation B when lenders use AI/Machine Learning systems to make lending decisions. EPIC specifically recommended that the agency rely on the Universal Guidelines for Artificial Intelligence, the OECD AI Principles, and scientific expertise in establishing regulatory guidance that requires explainability, transparency, and mitigation of bias in these systems. EPIC recommends agencies Government-wide enact similar regulations, and have urged Congress to enact federal baseline requirements about government use of AI and consumer privacy.
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