In this response, we present our comments to the Consultation Paper. We divide our comments into two parts. Section A provides specific input into the scope of principles set out in section 5 of the Consultation Paper. Building on our research on responsible and trustworthy AI in the digital lending sector, we present four considerations that may expand the scope of principles set out in Section 5 and further strengthen investor rights. Specifically, we suggest (1) mandating the institution of internal AI Ethical Review Boards that can align the design, development, deployment and performance of AI systems with ethical, legal, and regulatory norms, (b) laying greater emphasis on managing external counterparties through proportionate access rights, security checks and other safeguards, (c) contemplating a right of the investor to contest the decision of AI systems, and, (d) emphasise the creation of board-approved fairness policies to minimise bias and discrimination in the working of the AI systems. In Section B, we set out a list of best practices that operationalise the key requirements of responsible and trustworthy AI. The list of best practices is designed as a self-assessment questionnaire that allows financial service providers to score the strength of their existing safeguards and gauge their distance from the frontier of best practices. These may be considered to further enrich Annexure B of the Consultation Paper.
The response is available here.
Authorship: Beni Chugh based on the work with Manvi Khanna, PwC India and Sarada Mahesh.
