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challenges and the
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regulatory hurdle
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The difficulties seen in market simulation software
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illustrate some of the likely, wider challenges for
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generative AI. According to Cont, while generative AI
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tools can create new data sets, they will not include
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any new information if, for example, a company wants
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better insight into tail risk. More broadly, he adds, users
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cant just hope that a generic algorithm will extract
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what is needed for a niche use. If you dont target
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what you want to learn, you may not learn it, Cont
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explains. You have to ask what you want to use output
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for and then create a bespoke algorithm tailored to the
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intended use case. When you generate cat pictures
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from generative AI, you dont want a mutant cat, but
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in financial applications you are typically interested in
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extreme events.
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Reliability, bias, and accountability
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Additionally, checking the reliability of the output
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presents important challenges for activities that use
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substantial amounts of generated data. There is no
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easy way to validate the output, says Cont. If you
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want to feed these into a risk management framework
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or a portfolio optimization problem, youd better make
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sure that the output correctly captures the risk of the
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portfolio. That isnt obvious at all.
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In financial services, you will always have new
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products and new processes, which means that there
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will always be a need to retrain the models.
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Chia Hock Lai, Co-Founder, Global Fintech Institute
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20 MIT Technology Review Insights
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Other challenges with the technology, according to
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Mileham, include the classic issues of AI such as bias
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and accountability. According to a recent IMF study,
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generative AI, if anything, exacerbates these problems.
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The far greater breadth of data used to train LLMs, for
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example, leads to a greater theoretical possibility of
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bias. Similarly, the higher complexity of its architecture
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and decision-making processes compared to previous
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AI makes the reasoning behind given output more
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opaque.33 Very often, the sophisticated models of deep
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learning are black boxes, says Chia.
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Generative AI also poses its own specific challenges.
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These may arise even when the technology is working
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as planned. A recent study co-authored by Cont shows
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that algorithms that have learned from a common set
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of datasuch as the history of asset pricesmay end
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up synchronizing as if they were a cartel even though
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they are not communicating. If an algorithm learns to
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manipulate prices, can you sue anybody? asks Cont.
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It is a legal nightmare. This is one of the questions
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we are just beginning to study.34 Worse still, the
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potential for a herd-like response inherent in such an
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unconsciously coordinated response could present a
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threat to financial stability under a worst-case scenario,
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according to IMF research.35 Meanwhile, if generative AI
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sees increasing use for automated decision-making, it
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is likely to attract a high number of adversarial attacks.36
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Intellectual property rights and
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hallucinations
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Useful answers produced by generative AI may violate
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the IP rights of other actors, depending on the inputs
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used for training the model. Already, several artists
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have launched lawsuits based on the inclusion of their
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works in training data.37 Meanwhile, if a generative AI
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tool is trained on licensed software and generates new
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code, that may violate the IP rights of the licensor. At
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the same time, it is not a straightforward question in law
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if a company can license software created within its
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computer systems by generative AI with minimal or no
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human intervention.38
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Finally, things do not always work as planned.
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Hallucinations are the key bit, says Mileham, referring
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to incorrect content that can be generated confidently
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by AI, which brings substantial risk. A lawyer in U.S.
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federal court relying on ChatGPT recently submitted
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an affidavit in a personal injury lawsuit that included six
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fake cases. This led to substantial news coverage for
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the firm and potential sanctions.39 Hallucinations are a
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known problem but, so far, research to address them
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has focused on specific cases rather than the general
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issue.40
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These kinds of issues make rapid adoption of
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generative AI tools across a wider range of functions
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irresponsible. Institutional leaders must first assess
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the safety and security of these tools, and address
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any forthcoming challenges or risks, says Villanueva.
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Regulatory risks of a new technology
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Accountability is at the core of industry thinking on the
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rollout of generative AI. UBS research points to potential
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regulation as the main barrier to adoption of generative
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AI in the fintech space. Others argue that the same
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could be said of the entire financial sector. AI is not
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an easy button to use to bypass the accountability
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that we have to our customers, says Mileham.
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Regulators strongly agree. In a July 2023 speech,
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the chief executive of the UKs Financial Conduct
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Authority (FCA) reiterated: While the FCA does not
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regulate technology, we do regulate the effect on
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and use oftech in financial services.... With these
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