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AI governance in US financial services.

CFPB enforcement of AI in credit decisions, OCC model risk management for banks, adverse action notice requirements, SEC AI disclosure, and FTC consumer protection for financial AI.

Regulatory obligations at a glance

Key frameworks applying to AI in US financial services. Map your AI systems against each.

Adverse Action (ECOA)
CFPB

When AI denies credit or offers less favourable terms, specific reasons must be given. The CFPB has confirmed that "the model decided" is not a compliant adverse action reason — actual factors must be disclosed.

High
SR 26-2 Model Risk
OCC/Fed

Banks must apply model risk management principles to AI — validation, documentation, ongoing monitoring, and independent review. The "black box" defence does not satisfy prudential expectations.

High
FCRA Compliance
CFPB

AI using consumer report data must comply with FCRA requirements. AI credit models must accommodate adverse action notice requirements and consumer dispute processes.

High
FTC Section 5
FTC

AI practices that are unfair or deceptive — biased models, hidden AI use, or unsubstantiated capability claims — violate the FTC Act. Applies to all consumer-facing financial firms.

High
SEC AI Disclosure
SEC

Listed financial companies must disclose material AI risks. AI-generated investment research must comply with Regulation Best Interest. SEC has issued guidance on AI in investment advisory.

High
FINRA Suitability
FINRA

Algorithmic trading and AI in securities recommendations must comply with FINRA suitability rules — AI recommendations must be appropriate for individual clients.

High

Guidance and analysis

AI Governance in US Financial Services: SR 26-2, OCC, CFPB, and the Regulatory Framework

13 min read

AI Denied My Credit or Insurance in the US. What Are My Rights?

8 min read

AI Governance for US Small Businesses: FTC, State Privacy Laws, and What You Need to Do

8 min read

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