QUESTION
My main concern is that AI is about to take over my human responsibilities. It may come as a surprise, but I am a lawyer who serves as internal counsel for a lender in 35 states. You might think that a lawyer should have nothing to worry about when it comes to AI. I started here two years ago. The company continues to grow. There were four lawyers in our legal department. Yet, now there are three. One of them was fired, and in her place is an AI tool. I have a feeling that I am next to go!
What are we doing to ourselves? Why are we allowing AI to put us out of work and take our livelihoods from us? These are not humans, yet they can take our human knowledge, pose as humans, and replace us. I see the downsizing of AI replacing humans.
We are using your AI Policy Program to help us navigate AI’s compliance risks. It looks like AI is here to stay. AI regulations should protect consumers, and AI should not threaten our jobs!
I see slow-to-no AI regulations and very little understanding of how it will adversely affect humans.
What is being done to regulate artificial intelligence?
OUR COMPLIANCE SOLUTION
AI POLICY PROGRAM
FOR MORTGAGE BANKING™
Our AI Policy Program aligns
with Freddie Mac's and Fannie Mae’s requirements.
Our AI Policy Program consists of the
following policies:
1.
AI Governance Policy
2.
AI Use Policy
3.
AI Workplace Policy
4.
AI Credit Underwriting Policy
5.
AI Do & Do Not Policy
6.
AI Ethics Policy
7.
AI Vendor Management Policy
8.
AI Mortgage Fraud Policy
9.
AI Anti-Money Laundering
Policy
RESPONSE
You say AI is not human, and it certainly isn't. Indeed, the Internet and its derivatives, such as social media, are not human. The Internet, social media, and AI are all inanimate, lifeless, insentient, spiritless, uninhabited, inorganic, labyrinthine, concatenating chains that are composed of winding strands of human meaning.
These chains have no significance other than the understanding we invent for them. They are not our essence. We follow those chains, each of them like endless sands on a vast beach. The sands are unlimited, but the ones in our hourglass are finite.
We are Hansel and Gretel, following breadcrumbs that lead to the cannibalistic witch. Inevitably, these brute, cold, insensate vessels into which we pour our being do not know we are there. They are numb, dumb, and oblivious, soullessly mimicking us, like an alien intelligence whose center is everywhere.
Attempts to regulate AI technologies have not shown much foresight. Some of this negligence is by design and stems from an inability to recognize its implications. The mad dash into a new, unregulated, or semi-regulated technology is hubris borne of money, politics, and ego. AI technologies are expanding at a rate that outpaces the development of regulatory frameworks to mitigate their risks.
The alien intelligence is ready for us. Are we ready for it?
Over the past year,
federal regulators have sharply pulled back on AI-related enforcement,
including fair lending. The CFPB has scaled back liability for disparate impact
under ECOA. Bank examiners are conducting fewer fair lending risk assessments.
The administration has made deregulation its explicit policy goal. It would be
easy to read this as a green light. It isn't.
"Deregulation" Doesn't Mean Lower Risk
What's actually happening is a shift in venue, not a reduction in exposure. Enforcement is moving from Washington to state attorneys general, private litigation, and a separate federal statute that nobody has rolled back. For mortgage originators and servicers using AI in underwriting, pricing, marketing, or servicing, the practical compliance burden hasn't gone away. It is just coming from different directions, and those directions are harder to predict than a single federal rulebook ever was.
