On March 31, 2021 the OCC, Federal Reserve, FDIC, CFPB, and NCUA jointly published a Request for Information on financial institutions' use of artificial intelligence, including machine learning — the first coordinated federal inquiry into bank AI. The OCC transmitted it as Bulletin 2021-17. It asked about explainability, data quality and bias, overfitting, cybersecurity, dynamic updating, third-party AI, and fair-lending compliance, and whether existing guidance was adequate. Comments were originally due June 1, 2021 and the deadline was extended to July 1, 2021. No AI-specific rule followed; the agencies instead relied on model risk management and fair-lending law.
| Document | 2021 Interagency AI RFI (OCC Bulletin 2021-17) — Request for Information and Comment on Financial Institutions' Use of Artificial Intelligence, Including Machine Learning |
| Issued by | Office of the Comptroller of the Currency |
| Type | Consultation |
| Status | Final |
| Published | Mar 31, 2021 |
| Comment deadline | Jul 1, 2021 |
| Applies to | All insured depository institutions and credit unions supervised by the OCC, Federal Reserve, FDIC, CFPB, and NCUA (information request; no obligations) |
| Also issued as | 2021 Interagency AI RFI, FDIC FIL-20-2021, 2021 Interagency AI RFI |
| Official source | federalregister.gov ↗ |
| Use cases | AI governance (general) · Credit scoring & underwriting · Fair lending & discrimination · AML / KYC · Fraud detection · Customer-facing chatbots · Third-party & vendor AI |
What are the key points of 2021 Interagency AI RFI (OCC Bulletin 2021-17)?
- Five agencies: OCC, Federal Reserve Board, FDIC, CFPB, and NCUA; published in the Federal Register on March 31, 2021 (86 FR 16837).
- Sought information on AI uses including fraud detection, credit underwriting, customer service chatbots, AML/BSA monitoring, and cybersecurity.
- Listed risk topics: explainability, broader or more intensive data use, overfitting, cybersecurity, dynamic updating, use by community institutions, third-party oversight, and fair lending.
- Asked whether existing guidance — the 2011 model risk management guidance, third-party risk guidance, and consumer-protection law — sufficiently addressed AI.
- Comment deadline extended from June 1 to July 1, 2021.
- Did not itself impose requirements; its practical result was to confirm that AI would be supervised through existing frameworks rather than a new AI rule.
What did 2021 Interagency AI RFI (OCC Bulletin 2021-17) change for banks?
The RFI changed nothing legally, but it fixed the federal vocabulary for AI risk in banking (explainability, dynamic updating, third-party AI) that examiners still use, and its conclusion — no new AI rule, rely on model risk management and fair-lending law — set the posture that lasted until the 2026 model risk revision. The 2026 guidance's promise of a new AI-focused RFI is effectively a sequel to this one.
Did the 2021 interagency AI RFI result in any rule?
No. The five agencies gathered comments (deadline extended to July 1, 2021) but did not issue an AI-specific rule; AI has continued to be supervised through model risk management, third-party risk, and fair-lending frameworks.
What is OCC Bulletin 2021-17?
It is the OCC's transmittal of the March 31, 2021 interagency Request for Information on financial institutions' use of AI and machine learning, issued jointly with the Fed, FDIC, CFPB, and NCUA.
| Date | Document | Status |
|---|---|---|
| May 7, 2026 | OCC Semiannual Risk Perspective, Spring 2026 — Semiannual Risk Perspective from the National Risk Committee, Spring 2026 | Final |
| Apr 17, 2026 | OCC Bulletin 2026-13 — Model Risk Management: Revised Guidance | In force |
| Apr 29, 2025 | Acting Comptroller Hood, 'AI in Financial Services' (Apr 2025) — Remarks by Acting Comptroller Rodney E. Hood at the National Fair Housing Alliance's Responsible AI Symposium: 'AI in Financial Services' | Final |
| Jun 6, 2023 | OCC Bulletin 2023-17 — Third-Party Relationships: Interagency Guidance on Risk Management | In force |
| Apr 9, 2021 | OCC Bulletin 2021-19 — Bank Secrecy Act/Anti-Money Laundering: Interagency Statement on Model Risk Management for Bank Systems Supporting BSA/AML Compliance and Request for Information | Superseded |
| Apr 4, 2011 | OCC Bulletin 2011-12 — Sound Practices for Model Risk Management: Supervisory Guidance on Model Risk Management | Superseded |
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