Episode 4 speaker Avi Gesser co-authored a piece with Debevoise colleagues in November 2021 entitled “Increased Focus by Federal Regulators on AI and Consumer Protection in the Financial Sector”.  Among other possible steps to consider in mitigating risk, the article suggests:

  • “Developing an inventory of AI and machine learning models and establishing a risk-assessment framework for AI uses that considers the company’s legal, regulatory, compliance, operational and reputational risks”
  • “Considering whether the company can explain how its algorithms arrived at decisions with significant consumer implications, as well as what information should be provided to consumers about the consequences of automated decision-making, the key factors underpinning any adverse actions and how to contest or correct an erroneous determination”.

Read the full piece here.