Democrats on the House Financial Services Committee, led by Ranking Member Maxine Waters [D-Calif.], yesterday issued a Request for Information seeking public feedback on how AI is being used across the financial marketplace and what a modernized federal AI framework should look like.
Why it matters: The 54-question RFI is a roadmap to the issues Democrats intend to prioritize if and when they regain the gavel, and several of them land squarely on the collections industry. The RFI asks what explainability standards should be required when AI systems make decisions that affect consumers, such as credit denials, a question that follows the Consumer Financial Protection Bureau’s rescission of 67 guidance documents in May 2025, including its guidance requiring lenders to provide specific and accurate reasons for adverse actions generated by AI.
The document also zeroes in on third-party vendor risk, a pressing issue for creditors and agencies alike that rely on outside AI providers. Regulators have warned about a “monoculture of models” in which financial institutions all depend on the same handful of vendors, and the RFI asks what Congress should do to maintain oversight of those vendors, particularly, in the Committee Democrats’ words, during periods of reduced agency enforcement and supervision.
Other questions probe liability. The RFI asks what responsibility financial institutions and their third-party service providers should bear when AI contributes to violations of federal law, whether statutes like the Equal Credit Opportunity Act and Fair Credit Reporting Act need amending, and whether safe harbors are warranted. It also flags open questions about whether AI agents that initiate transactions are covered by the Truth in Lending Act and Electronic Fund Transfer Act.
Between the lines: The RFI arrives amid regulatory whiplash. Federal banking agencies in April replaced the longstanding SR 11-7 model risk management guidance with a revised version that excludes generative and agentic AI from its scope, leaving firms without clear supervisory expectations for exactly the models they are most eager to adopt. Meanwhile, the Trump Administration has pushed to preempt state AI laws while dialing back federal enforcement.
