# 2021 Interagency AI RFI: Request for Information and Comment on Financial Institutions' Use of Artificial Intelligence, Including Machine Learning

Source: https://www.bankingnewsai.com/ai-regulation/documents/ncua-interagency-ai-rfi-2021
Last updated: Aug 26, 2026

On March 29, 2021 the NCUA joined the OCC, Federal Reserve, FDIC, and CFPB in a request for information on financial institutions' use of AI and machine learning, published in the Federal Register on March 31, 2021. It asked 17 questions on explainability, data quality, dynamic updating, overfitting, cybersecurity, fair lending, third-party AI, and community-institution challenges. The comment period was extended from June 1 to July 1, 2021; the agencies never issued follow-on interagency AI guidance.

## At a glance

| Field | Value |
| --- | --- |
| Authority | [NCUA](https://www.bankingnewsai.com/ai-regulation/ncua) |
| Type | Consultation |
| Status | Final |
| Published | Mar 31, 2021 |
| Comment deadline | Jul 1, 2021 |
| Applies to | Banks, credit unions, and other financial institutions supervised by the OCC, Federal Reserve, FDIC, CFPB, and NCUA |
| Official text | https://www.federalregister.gov/documents/2021/03/31/2021-06607/request-for-information-and-comment-on-financial-institutions-use-of-artificial-intelligence-including-machine-learning |

## Key points

- First coordinated federal look at bank and credit union AI; the NCUA's participation brought credit unions inside the scope
- Use cases named: fraud detection, credit underwriting, customer service personalization, AML, textual analysis, cybersecurity
- Questions on explainability, risks from broader or alternative data, dynamic updating, overfitting, cybersecurity, fair lending, and reliance on third-party AI
- Explicitly asked about challenges for community institutions, which describes most credit unions (two-thirds hold under $100 million in assets)
- Comment deadline extended to July 1, 2021 at stakeholders' request
- Cited existing frameworks (SR 11-7 model risk, third-party guidance, ECOA/Reg B adverse action) as the current rulebook

## What changed for banks

The RFI signalled that AI would be supervised through existing law rather than new rules, a posture the NCUA still holds five years later. For credit unions it is the only interagency AI document the NCUA has signed; subsequent model risk and AI issuances by the bank regulators (2026 model risk guidance) did not include the NCUA.

## Use cases it governs

- [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)
- [Fair lending & discrimination](https://www.bankingnewsai.com/ai-regulation/by-use-case#fair-lending)
- [Third-party & vendor AI](https://www.bankingnewsai.com/ai-regulation/by-use-case#third-party-vendors)
- [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), [FDIC FIL-20-2021](https://www.bankingnewsai.com/ai-regulation/documents/fdic-fil-20-2021).

## FAQ

### Did the 2021 AI RFI lead to any rule?

No. No interagency AI rule or guidance followed. The agencies have addressed AI through existing frameworks, and the OCC, Fed, and FDIC revised model risk guidance in April 2026 without the NCUA.

### Why does the RFI matter for credit unions?

It is the NCUA's clearest statement of the AI risk themes examiners care about: explainability, data quality, fair lending, and third-party dependence.

## Related documents

- [Hauptman Senate testimony (Feb 2026)](https://www.bankingnewsai.com/ai-regulation/documents/ncua-hauptman-senate-testimony-2026) — Written Testimony of NCUA Chairman Kyle S. Hauptman before the U.S. Senate Committee on Banking, Housing, and Urban Affairs (Feb 12, 2026)
- [NCUA Letter 26-CU-01](https://www.bankingnewsai.com/ai-regulation/documents/ncua-letter-26-cu-01) — NCUA's 2026 Supervisory Priorities (Jan 14, 2026)
- [NCUA AI Compliance Plan (2025)](https://www.bankingnewsai.com/ai-regulation/documents/ncua-ai-compliance-plan-2025) — NCUA Artificial Intelligence Compliance Plan (Sep 1, 2025)
- [NCUA Credit Union AI Resource Center](https://www.bankingnewsai.com/ai-regulation/documents/ncua-credit-union-ai-resource-center) — Artificial Intelligence (AI) — Credit Union AI Resource Center and AI Resources page (Aug 1, 2025)
- [NCUA Board AI briefing (Jul 2025)](https://www.bankingnewsai.com/ai-regulation/documents/ncua-ai-board-briefing-2025) — Board Briefing: Artificial Intelligence and Its Use Within the Credit Union Industry and the NCUA (Jul 24, 2025)
- [NCUA Financial Innovation Rule (2023)](https://www.bankingnewsai.com/ai-regulation/documents/ncua-financial-innovation-rule-2023) — Financial Innovation: Loan Participations, Eligible Obligations, and Notes of Liquidating Credit Unions (final rule) (Sep 21, 2023)
- [NCUA testimony to House AI Task Force (2022)](https://www.bankingnewsai.com/ai-regulation/documents/ncua-ai-task-force-testimony-2022) — Written Testimony of Kelly Lay, Director of the Office of Examination and Insurance, before the House Financial Services Task Force on Artificial Intelligence (May 13, 2022)
- [NCUA Letter 07-CU-13](https://www.bankingnewsai.com/ai-regulation/documents/ncua-letter-07-cu-13) — Evaluating Third Party Relationships (Dec 1, 2007)

Last reviewed Aug 26, 2026. Cite the official text (https://www.federalregister.gov/documents/2021/03/31/2021-06607/request-for-information-and-comment-on-financial-institutions-use-of-artificial-intelligence-including-machine-learning) for the rule and this page for the summary and dates.

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