# FDIC FIL-20-2021: Request for Information and Comment on Financial Institutions' Use of Artificial Intelligence, Including Machine Learning

Source: https://www.bankingnewsai.com/ai-regulation/documents/fdic-fil-20-2021
Last updated: Aug 26, 2026

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.

## At a glance

| Field | Value |
| --- | --- |
| Authority | [FDIC](https://www.bankingnewsai.com/ai-regulation/fdic) |
| Type | Consultation |
| Status | Final |
| Published | Mar 29, 2021 |
| Comment deadline | Jul 1, 2021 |
| Applies to | All FDIC-supervised financial institutions (informational; no obligations) |
| Official text | https://www.fdic.gov/news/financial-institution-letters/2021/fil21020.html |

## Key points

- 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 changed 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.

## Use cases it governs

- [AI governance (general)](https://www.bankingnewsai.com/ai-regulation/by-use-case#governance-general)
- [Credit scoring & underwriting](https://www.bankingnewsai.com/ai-regulation/by-use-case#credit-underwriting)
- [Fraud detection](https://www.bankingnewsai.com/ai-regulation/by-use-case#fraud)
- [Model risk management](https://www.bankingnewsai.com/ai-regulation/by-use-case#model-risk)

Same interagency text issued as: [2021 Interagency AI RFI](https://www.bankingnewsai.com/ai-regulation/documents/fed-interagency-ai-rfi-2021), [2021 Interagency AI RFI (OCC Bulletin 2021-17)](https://www.bankingnewsai.com/ai-regulation/documents/occ-bulletin-2021-17-ai-rfi), [2021 Interagency AI RFI](https://www.bankingnewsai.com/ai-regulation/documents/ncua-interagency-ai-rfi-2021).

## FAQ

### 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.

## Related documents

- [Hill House oversight testimony (Jun 2026)](https://www.bankingnewsai.com/ai-regulation/documents/fdic-testimony-oversight-prudential-regulators-2026) — Statement of Chairman Travis Hill: Oversight of Prudential Regulators (Jun 4, 2026)
- [FDIC FIL-15-2026](https://www.bankingnewsai.com/ai-regulation/documents/fdic-fil-15-2026) — Agencies Revise the Interagency Model Risk Management Guidance (Apr 17, 2026)
- [FDIC House testimony on AI and innovation (Mar 2026)](https://www.bankingnewsai.com/ai-regulation/documents/fdic-testimony-innovation-speed-of-markets-2026) — Innovation at the Speed of Markets: How Regulators Keep Pace with Technology (Mar 26, 2026)
- [FDIC 2025 Report on Cybersecurity and Resilience](https://www.bankingnewsai.com/ai-regulation/documents/fdic-cybersecurity-resilience-report-2025) — 2025 Report on Cybersecurity and Resilience (Jul 14, 2025)
- [Hill 'Charting a New Course' speech](https://www.bankingnewsai.com/ai-regulation/documents/fdic-charting-new-course-speech-2025) — Charting a New Course: Preliminary Thoughts on FDIC Policy Issues (Jan 10, 2025)
- [FDIC 2024 Risk Review](https://www.bankingnewsai.com/ai-regulation/documents/fdic-risk-review-2024) — 2024 Risk Review — Section 5: Operational and Cyber Risks (May 22, 2024)
- [FDIC FIL-29-2023](https://www.bankingnewsai.com/ai-regulation/documents/fdic-fil-29-2023) — Interagency Guidance on Third-Party Relationships: Risk Management (Jun 6, 2023)
- [FDIC FIL-27-2021](https://www.bankingnewsai.com/ai-regulation/documents/fdic-fil-27-2021) — Interagency Statement on Model Risk Management for Bank Systems Supporting BSA/AML and OFAC Compliance (Apr 9, 2021)

Last reviewed Aug 26, 2026. Cite the official text (https://www.fdic.gov/news/financial-institution-letters/2021/fil21020.html) for the rule and this page for the summary and dates.

---

Canonical page: https://www.bankingnewsai.com/ai-regulation/documents/fdic-fil-20-2021
Part of [BankingNewsAI](https://www.bankingnewsai.com/) — a free daily brief on AI in banking, an AI regulation tracker (41 authorities, 237 documents) and AI-strategy profiles of the 120 largest US banks. Markdown versions of every reference page: append `.md` to the page URL; index at https://www.bankingnewsai.com/llms.txt.