Amid recent technological advances in artificial intelligence and machine learning, on January 17, 2025, the CFPB issued its Winter 2025 Supervisory Highlights: Advanced Technologies Special Edition. This edition of...more
Welcome to this week's issue of AI: The Washington Report, a joint undertaking of Mintz and its government affairs affiliate, ML Strategies. The accelerating advances in artificial intelligence (“AI”) and the practical,...more
Recent Consumer Financial Protection Bureau ("CFPB") guidance reiterates that creditors must provide consumers with accurate and individualized explanations for adverse actions—a task made more difficult by the complexity of...more
In May 2022, the CFPB issued Circular 2022-3 addressing Equal Credit Opportunity Act (ECOA) adverse action notice requirements in connection with credit decisions based on algorithms. The CFPB is now revisiting the issue in...more
When using artificial intelligence (AI) or complex credit models, can lenders rely on the checklist of reasons provided in Regulation B sample forms for adverse action notices? According to today’s guidance issued by the...more
On May 26th, 2022, the Consumer Financial Protection Bureau (“CFPB”) published a Consumer Financial Protection Circular (the “Circular”), confirming that creditors must provide specific reasons for taking adverse action...more
The FTC has sent its annual letter to the CFPB reporting on the FTC’s activities related to compliance with the Equal Credit Opportunity Act and Regulation B. ...more