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Artificial Intelligence (AI) models used by banks and lenders must be carefully designed, tested, and monitored to ensure they do not reinforce and amplify historic discrimination and redlining against Black Americans and other communities of color, according to comments submitted to several federal financial regulators. The Lawyers’ Committee for Civil Rights Under Law and other advocacy groups submitted these comments on Thursday.   

In the housing and lending sectors, decades of discriminatory patterns have disproportionately impacted Black Americans and other communities of color. AI models, including those used by financial services firms, often contain biases that replicate these disparities. The groups are calling on federal agencies to conduct an in-depth review of the use of AI in financial services, and set clear and robust regulations to ensure that, going forward, any AI models that are used are equitable and nondiscriminatory. 

“This is an opportune moment for federal agencies to take bold action on discriminatory technology, and do their part in helping tear down systemic racism in our society,” said Adonne Washington, a legal fellow in the Digital Justice Initiative at the Lawyers’ Committee for Civil Rights Under Law. “For far too long, unjust lending and housing practices have prevented Black Americans and other communities of color from securing a home and accessing economic opportunities. These agencies can be more effective by moving quickly to institute necessary, strong reforms and guidelines for AI.” 

The comments responded to a request for information from the Department of the Treasury, Federal Reserve, Federal Deposit Insurance Corporation, Consumer Financial Protection Bureau, National Credit Union Administration, and the Office of the Comptroller of the Currency.  

Read the comment here.  



About the Lawyers’ Committee for Civil Rights Under Law – The Lawyers’ Committee for Civil Rights Under Law (Lawyers’ Committee), a nonpartisan, nonprofit organization, was formed in 1963 at the request of President John F. Kennedy to involve the private bar in providing legal services to address racial discrimination. The principal mission of the Lawyers’ Committee for Civil Rights Under Law is to secure, through the rule of law, equal justice for all, particularly in the areas of voting rights, criminal justice, fair housing and community development, economic justice, educational opportunities, and hate crimes.  For more information, please visit