On March 29, 2021 the FDIC issued FIL-20-2021 transmitting the first coordinated federal request for information on banks' use of AI and machine learning, issued jointly with the Federal Reserve, OCC, CFPB, and NCUA (FDIC docket RIN 3064-ZA24). Published in the Federal Register on March 31, 2021, it asked how institutions use AI, what governance, risk management, and controls they apply, what challenges they face, and whether regulatory clarification would help. Comments were originally due June 1, 2021 and, after an extension announced in FIL-34-2021, closed July 1, 2021.
| Document | FDIC FIL-20-2021 — Request for Information and Comment on Financial Institutions' Use of Artificial Intelligence, Including Machine Learning |
| Issued by | Federal Deposit Insurance Corporation |
| Type | Consultation |
| Status | Final |
| Published | Mar 29, 2021 |
| Comment deadline | Jul 1, 2021 |
| Applies to | All FDIC-supervised financial institutions (informational; no obligations) |
| Also issued as | 2021 Interagency AI RFI, 2021 Interagency AI RFI (OCC Bulletin 2021-17), 2021 Interagency AI RFI |
| Official source | fdic.gov ↗ |
| Use cases | AI governance (general) · Credit scoring & underwriting · Fraud detection · Model risk management |
What are the key points of FDIC FIL-20-2021?
- Five-agency RFI: FDIC, Federal Reserve, OCC, CFPB, and NCUA; Federal Register publication March 31, 2021.
- Asked about AI use cases including fraud prevention, customer-service personalization, and credit underwriting, plus explainability, data quality, dynamic updating, and third-party AI.
- Sought views on governance, risk management, and controls over AI and on whether existing laws and guidance needed clarification.
- Comment deadline extended from June 1 to July 1, 2021 (FIL-34-2021).
- No interagency AI rule or guidance resulted directly; the agencies instead revisited model risk management, culminating in the April 2026 revision.
What did FDIC FIL-20-2021 change for banks?
The RFI created no obligations but established the federal supervisors' shared framing of AI risk — explainability, data, overfitting, dynamic updating, and third-party dependence — that examiners have used since. It is the reference point news stories cite when noting that regulators have studied bank AI for five years without an AI-specific rule.
Did the 2021 AI RFI lead to any rule?
No. The agencies did not issue an AI-specific rule or guidance from the 2021 RFI. Its themes fed into supervisory practice and, ultimately, the April 2026 revised interagency model risk management guidance.
When did comments on the 2021 AI RFI close?
July 1, 2021. The original June 1 deadline was extended by 30 days, announced by the FDIC in FIL-34-2021.
| Date | Document | Status |
|---|---|---|
| Jun 4, 2026 | Hill House oversight testimony (Jun 2026) — Statement of Chairman Travis Hill: Oversight of Prudential Regulators | Final |
| Apr 17, 2026 | FDIC FIL-15-2026 — Agencies Revise the Interagency Model Risk Management Guidance | In force |
| Mar 26, 2026 | FDIC House testimony on AI and innovation (Mar 2026) — Innovation at the Speed of Markets: How Regulators Keep Pace with Technology | Final |
| Jul 14, 2025 | FDIC 2025 Report on Cybersecurity and Resilience — 2025 Report on Cybersecurity and Resilience | Final |
| Jan 10, 2025 | Hill 'Charting a New Course' speech — Charting a New Course: Preliminary Thoughts on FDIC Policy Issues | Final |
| May 22, 2024 | FDIC 2024 Risk Review — 2024 Risk Review — Section 5: Operational and Cyber Risks | Final |
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