5 Ways To Avoid The Consumer Financial Protection Bureau’s ‘Dangers From Poorly Deployed Chatbots’

How to address AI chatbot concerns raised by the CFPB

Earlier this summer the US Consumer Financial Protection Bureau published an issue spotlight on the dangers to consumers posed by poorly deployed chatbots at banks and credit unions nationally. With a domain as sensitive to consumers as the financial industry, it is paramount that the customer service tools provided to them are trustworthy. When used correctly, virtual assistants are an incredibly powerful tool that can provide efficiency, convenience, and cost savings to any organization. A poorly implemented chatbot can, however, cause more harm than good and lead to both dissatisfied users, and even possibly legal troubles. 

So, how can you avoid the pitfalls and dangers of deploying a virtual assistant and make sure you’re providing customers or members the best possible solution? If we take a look at the CFPB’s major concerns, a framework for success emerges:

Chatbots that don’t understand complex issues

Transaction-related disputes are a high volume request from customers and members at many banks and credit unions. The CFPB points out that rules-based or keyword-based bots recognize these types of questions very poorly, as they rely on a limited number of triggers to decide on what a user is asking. These, and other similarly complex issues, can serve as blindspots that simple chatbots are unable to recognize and assist with. Banks and credit unions can avoid this pitfall by deploying larger and more sophisticated AI language understanding models that are able to better understand what users are asking. Modern solutions that do this today leverage Large Language Models, the same underlying technology that powers ChatGPT, and are trained on very large datasets of real-world conversations. This combination of sophisticated AI models and a large volume of conversation data specifically about banking enables the chatbot to be better equipped to understand users’ more complicated needs.

Chatbots that aren’t very helpful 

The CFPB highlights that AI often seems highly sophisticated on the surface, but in practice can provide customers and members with a frustrating experience that’s barely better than an FAQ page. Furthermore, simple bots or those with only a narrow level of topic coverage and/or shallow level of depth can be difficult to use, especially for users who have limited English proficiency. The solution here is to give your account holders access to a virtual assistant that understands the channel it’s in and can provide them specific, granular responses to their questions that are configured to provide the best answer rather than just pulling information from or providing a link to a general FAQ. Sophisticated virtual assistant solutions can even sometimes perform tasks automatically for users, such as providing account specific information and helping them navigate online banking to complete their tasks.

Providing inaccurate, unreliable, or insufficient information

One of the biggest concerns surfaced by the CFPB is the possibility of VAs providing consumers with information that is just plain wrong, which could have detrimental effects on their financial wellbeing and erode trust between them and their bank or credit union. Keeping information accurate and up to date is critical to ensuring account holders find resolutions to their problems, and ensuring that your bank or credit union stays on the right side of consumer financial protection laws. The key to this is ensuring your team has timely control over the information the VA shows to your users – if information about an interest rate needs to be changed, then it can’t wait for your VA provider to act on a ticket. It’s critical your team can make that change on their own and get it live immediately before your chatbot gets a chance to provide incorrect information.

Another danger to accuracy the CFPB brings up is a topic that’s on everybody’s mind these days: Generative AI. Generative AI systems, such as ChatGPT, are truly groundbreaking, but at this time are not yet ready to be the face of your financial institution to your customers or members. Across the board these models struggle with telling the difference between fact and fiction, and as the CFPB points out, consumers often can’t tell the difference, either. Furthermore, you have little to no control over exactly what a Generative AI model will say to your consumers, so using one as a customer-facing chatbot runs the risk of it saying something you really don’t want it to say.

Making it impossible to talk to a human being

The CFPB goes on to point out that financial conversations often leave a customer or member feeling anxious, stressed, confused, or frustrated before they even start their interaction with a VA, and then many banks or credit unions make it close to impossible to talk to a real human service agent. For sensitive financial issues, people often feel much more comfortable speaking with a real human agent rather than an automated system, so providing easy access to your live staff is vital. It is important to consider your VA a member of your support team, not a replacement: The VA can assist customers or members with the majority of their routine and repetitive needs, but it should be able to offer a seamless escalation to your human team when needed or requested.

Security, Privacy & PII Concerns

Last but certainly not least, the CFPB raised the alarm on problems that could exist in virtual assistant technology related to security, privacy and personally identifiable information (PII). Any technology that your customers or members interact with could pose a danger, but this can be mitigated by ensuring you work with a company that focuses on the financial industry as they will be critically aware of your compliance needs and concerns and will have security front of mind with everything they design. The digital-first world demands security and reliability, so you should expect the same from your technology providers.

The Consumer Financial Protection Bureau provides an important service in ensuring that consumers across the US are treated fairly by their financial institutions. Their concerns around the growing number of chatbots and virtual assistants are well founded, but by closely heeding their research and recommendations you can ensure you deploy a virtual assistant that will save your customers or members time, ensure they can access necessary information 24/7, and connect to your live representatives when they need to—truly becoming a member of your team in providing the best possible service!