The CFPB recently issued an “issue spotlight” to address concerns with the use of “chatbots”. It has apparently received “numerous” complaints from individuals who have tried to interact with this form of artificial intelligence when looking for answers from their financial institutions. Some chatbots have names; some try to respond using machine learning/technology; and some dictate how a user may proceed by limiting the user’s options. Recently, even more advanced “generative chatbots”, have been used for customer service needs. The CFPB notes:
Financial institutions are increasingly using chatbots as a cost-effective alternative to human customer service.
Chatbots may be useful for resolving basic inquiries, but their effectiveness wanes as problems become more complex.
Financial institutions risk violating legal obligations, eroding customer trust, and causing consumer harm when deploying chatbot technology.
The CFPB is concerned that chatbots are ineffective and unable to provide meaningful assistance, especially as questions get more complex. The CFPB does not believe institutions should use a chatbot …as their primary customer service delivery channel when it is reasonably clear that the chatbot is unable to meet customer needs. The point being, even chatbots must be in compliance. Here are some specific concerns noted by the CFPB:
1. Limited ability to solve complex problems
- Difficulties in recognizing and resolving peoples’ disputes.
- Providing inaccurate, unreliable, or insufficient information
- Failure to provide meaningful customer assistance
2. Hindering access to timely human intervention
3. Technical limitations and associated security risks
- System reliability and downtime
- Security risks posed by impersonation and phishing scams
- Keeping personally identifiable information safe
- Risk of noncompliance with federal consumer financial law
- Risk of diminished customer service and trust when chatbots reduce access to individualized human support agents
- Risk of harming people
Ultimately, institutions using chatbots in any form need to understand the limitations involved with their use and the reality that the institution may be responsible for any resulting harm.
Published
2023/06/30
