# CFPB comment to Treasury on AI in financial services (2024): CFPB Comment on Request for Information on Uses, Opportunities, and Risks of Artificial Intelligence in the Financial Services Sector

Source: https://www.bankingnewsai.com/ai-regulation/documents/cfpb-comment-treasury-ai-rfi-2024
Last updated: Aug 26, 2026

On August 12, 2024 the CFPB responded to Treasury's June 2024 RFI on AI in financial services, stating that there is 'no fancy new technology carveout' to federal consumer financial law. The comment named chatbots, fraud-detection models, algorithmic underwriting and pricing as areas of compliance risk, stressed that fair-lending testing of complex models must include a search for less discriminatory alternatives, and explained why the Bureau had ended its sandbox and no-action-letter programs.

## At a glance

| Field | Value |
| --- | --- |
| Authority | [CFPB](https://www.bankingnewsai.com/ai-regulation/cfpb) |
| Type | Letter |
| Status | Final |
| Published | Aug 12, 2024 |
| Applies to | Providers of consumer financial products using AI, including for chatbots, fraud screening, underwriting and pricing |
| Official text | https://www.consumerfinance.gov/archive/newsroom/cfpb-comment-on-request-for-information-on-uses-opportunities-and-risks-of-artificial-intelligence-in-the-financial-services-sector/ |

## Key points

- Existing laws (ECOA, FCRA, EFTA, UDAAP) apply fully to AI; the Bureau will assess AI uses against them.
- Chatbots must give accurate information and honor dispute and error-resolution obligations.
- Algorithmic lending and fraud-screening tools must meet ECOA standards, including adverse-action notices.
- Fair-lending testing of complex models should include searching for less discriminatory alternatives (LDAs).
- Warns about algorithmic pricing and use of personal data to set prices, and about firms marketing AI while obscuring product terms.
- Rejects firm-specific regulatory sandboxes and no-action letters as unfair competitive advantages that waived protections.
- Now hosted in the CFPB archive, reflecting the 2025 change in Bureau leadership.

## What changed for banks

It is the fullest single statement of the pre-2025 CFPB's AI position and the source of the widely quoted 'no fancy new technology carveout' line. The LDA-search expectation it endorsed has been undercut by the 2026 Regulation B rule eliminating disparate-impact liability, but the chatbot, fraud and adverse-action points rest on statutory provisions that remain in force.

## Use cases it governs

- [AI governance (general)](https://www.bankingnewsai.com/ai-regulation/by-use-case#governance-general)
- [Customer-facing chatbots](https://www.bankingnewsai.com/ai-regulation/by-use-case#customer-chatbots)
- [Fraud detection](https://www.bankingnewsai.com/ai-regulation/by-use-case#fraud)
- [Credit scoring & underwriting](https://www.bankingnewsai.com/ai-regulation/by-use-case#credit-underwriting)
- [Fair lending & discrimination](https://www.bankingnewsai.com/ai-regulation/by-use-case#fair-lending)

## FAQ

### Did the CFPB tell Treasury it needed new AI rules?

No. Its August 2024 comment argued that existing consumer-protection laws already cover AI and that uniform enforcement, not special AI regimes or sandboxes, best supports innovation.

## Related documents

- [Regulation B final rule on disparate impact (April 2026)](https://www.bankingnewsai.com/ai-regulation/documents/cfpb-regulation-b-final-rule-2026) — Equal Credit Opportunity Act (Regulation B) — final rule amending disparate impact, discouragement and special purpose credit program provisions (Apr 22, 2026)
- [CFPB withdrawal of 67 guidance documents (May 2025)](https://www.bankingnewsai.com/ai-regulation/documents/cfpb-guidance-withdrawal-2025) — Interpretive Rules, Policy Statements, and Advisory Opinions; Withdrawal (May 12, 2025)
- [CFPB Circular 2023-03](https://www.bankingnewsai.com/ai-regulation/documents/cfpb-circular-2023-03) — Adverse action notification requirements and the proper use of the CFPB's sample forms provided in Regulation B (Sep 19, 2023)
- [CFPB Chatbots in Consumer Finance (issue spotlight, 2023)](https://www.bankingnewsai.com/ai-regulation/documents/cfpb-chatbots-in-consumer-finance-2023) — Chatbots in consumer finance (Jun 6, 2023)
- [Joint Statement on Automated Systems (CFPB, DOJ, EEOC, FTC)](https://www.bankingnewsai.com/ai-regulation/documents/cfpb-joint-statement-automated-systems-2023) — Joint Statement on Enforcement Efforts Against Discrimination and Bias in Automated Systems (Apr 25, 2023)
- [CFPB Circular 2022-03](https://www.bankingnewsai.com/ai-regulation/documents/cfpb-circular-2022-03) — Adverse action notification requirements in connection with credit decisions based on complex algorithms (May 26, 2022)
- [CFPB Innovation Spotlight on AI/ML adverse action notices (2020)](https://www.bankingnewsai.com/ai-regulation/documents/cfpb-innovation-spotlight-ai-ml-adverse-action-2020) — Innovation spotlight: Providing adverse action notices when using AI/ML models (Jul 7, 2020)
- [ECOA / Regulation B adverse action (15 U.S.C. 1691(d); 12 CFR 1002.9)](https://www.bankingnewsai.com/ai-regulation/documents/cfpb-ecoa-regulation-b-adverse-action) — Equal Credit Opportunity Act section 701(d) and Regulation B section 1002.9 — notification of adverse action and statement of specific reasons (Oct 28, 1974)

Last reviewed Aug 26, 2026. Cite the official text (https://www.consumerfinance.gov/archive/newsroom/cfpb-comment-on-request-for-information-on-uses-opportunities-and-risks-of-artificial-intelligence-in-the-financial-services-sector/) for the rule and this page for the summary and dates.

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