# 2021 Interagency AI RFI (OCC Bulletin 2021-17): Request for Information and Comment on Financial Institutions' Use of Artificial Intelligence, Including Machine Learning

Source: https://www.bankingnewsai.com/ai-regulation/documents/occ-bulletin-2021-17-ai-rfi
Last updated: Aug 26, 2026

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.

## At a glance

| Field | Value |
| --- | --- |
| Authority | [OCC](https://www.bankingnewsai.com/ai-regulation/occ) |
| 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) |
| 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

- 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 changed 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.

## 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)
- [Fair lending & discrimination](https://www.bankingnewsai.com/ai-regulation/by-use-case#fair-lending)
- [AML / KYC](https://www.bankingnewsai.com/ai-regulation/by-use-case#aml-kyc)
- [Fraud detection](https://www.bankingnewsai.com/ai-regulation/by-use-case#fraud)
- [Customer-facing chatbots](https://www.bankingnewsai.com/ai-regulation/by-use-case#customer-chatbots)
- [Third-party & vendor AI](https://www.bankingnewsai.com/ai-regulation/by-use-case#third-party-vendors)

Same interagency text issued as: [2021 Interagency AI RFI](https://www.bankingnewsai.com/ai-regulation/documents/fed-interagency-ai-rfi-2021), [FDIC FIL-20-2021](https://www.bankingnewsai.com/ai-regulation/documents/fdic-fil-20-2021), [2021 Interagency AI RFI](https://www.bankingnewsai.com/ai-regulation/documents/ncua-interagency-ai-rfi-2021).

## FAQ

### 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.

## Related documents

- [OCC Semiannual Risk Perspective, Spring 2026](https://www.bankingnewsai.com/ai-regulation/documents/occ-semiannual-risk-perspective-spring-2026) — Semiannual Risk Perspective from the National Risk Committee, Spring 2026 (May 7, 2026)
- [OCC Bulletin 2026-13](https://www.bankingnewsai.com/ai-regulation/documents/occ-bulletin-2026-13) — Model Risk Management: Revised Guidance (Apr 17, 2026)
- [Acting Comptroller Hood, 'AI in Financial Services' (Apr 2025)](https://www.bankingnewsai.com/ai-regulation/documents/occ-hood-responsible-ai-speech-2025) — Remarks by Acting Comptroller Rodney E. Hood at the National Fair Housing Alliance's Responsible AI Symposium: 'AI in Financial Services' (Apr 29, 2025)
- [OCC Bulletin 2023-17](https://www.bankingnewsai.com/ai-regulation/documents/occ-bulletin-2023-17) — Third-Party Relationships: Interagency Guidance on Risk Management (Jun 6, 2023)
- [OCC Bulletin 2021-19](https://www.bankingnewsai.com/ai-regulation/documents/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 (Apr 9, 2021)
- [OCC Bulletin 2011-12](https://www.bankingnewsai.com/ai-regulation/documents/occ-bulletin-2011-12) — Sound Practices for Model Risk Management: Supervisory Guidance on Model Risk Management (Apr 4, 2011)
- [OCC Bulletin 1997-24](https://www.bankingnewsai.com/ai-regulation/documents/occ-bulletin-1997-24) — Credit Scoring Models: Examination Guidance (May 20, 1997)
- [SB 947](https://www.bankingnewsai.com/ai-regulation/documents/ca-sb-947-2026) — Employment: Automated Decision Systems (No Robo Bosses Act) (Sep 30, 2026)

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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