AI Chatbot intelligent digital customer service application concept Credit/AdobeStock

That is the key question that lenders of all shapes and sizes will be struggling with for years to come as they seek to utilize the paradigm shifting use of artificial intelligence within a framework of laws developed when AI was the stuff of fantasy gleaned from the latest episode of Star Trek. As things stand now, this resulting disconnect between technology and the law raises substantial compliance and legal risks that, if left unaddressed, pose challenges for even the biggest of credit unions and will inevitably exacerbate the increasing divide between large and small lenders within the credit union industry.

The field is so new that we don’t even have set terms to guide our legal and operational analysis. For purposes of this column, I like this description of AI provided by OCC’s Acting Comptroller of the Currency in a recent speech touching on these very topics: “AI systems, which are generally based on neural networks, are not programmed explicitly like most software. They require training, and their outputs are not predictable … [this] creates a fundamental problem: Since AI systems are built to ‘learn,’ they may or may not do what we want or behave consistent with our values.”


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