Independent Banker - September 2023 - 27

the potential for confidential data to
be exposed.
Generative AI learns from existing
information-everything it produces
is based on publicly available articles,
images and other content-so if an
organization doesn't have safeguards
in place, any information they put into
a generative AI tool can be picked up
by other tools.
Knowing the safeguards that are
available is, therefore, critical. For
example, ChatGPT introduced a
feature where a user can enable or
disable chat history. If chat history is
enabled, the user is basically giving
OpenAI-the chatbot's developer-
the right to use the data entered
to " retrain the model, " meaning it
becomes part of the universe of data
that ChatGPT can access.
Samsung is one company that
learned its lesson the hard way. It
banned the use of ChatGPT after
employees revealed sensitive company
information to the chatbot. " On the
data privacy side, every bank should
be concerned about employees putting
" We don't really want to put
out edicts that say, 'Thou
shall not use these tools.' "
-BARB MACLEAN, COASTAL COMMUNITY BANK
data into the ChatGPT interface with
chat history [and training] enabled, "
says Bharwani.
Creating a generative AI policy
Companies across industries are
looking at creating policies around
the use of generative AI tools, and the
fundamental question is: Should they
allow it at all? There isn't a one-sizefits-all
answer.
More from ICBA
Generative AI is the hottest
of topics, and ICBA has
resources that can help
you make sense of it.
 There will be a
Generative AI & ChatGPT
session at the ICBA LEAD
FWD Summit, Sept. 18-19
in Kansas City, Mo.
 Look out for the
" Demystifying Generative
AI & ChatGPT " webinar
series, launching soon!
When developing generative AI
policies, community banks need to
think about their own risk tolerance,
the culture of innovation within their
teams and what kind of guardrails or
parameters are appropriate, advises
Barb MacLean, senior vice president,
head of technology operations
and implementation at Coastal
Community Bank in Everett, Wash.
The $3.5 billion-asset community
bank takes a transparent, deliberate
approach to generative AI tools such
as ChatGPT. " We don't really want
to put out edicts that say, 'Thou shall
not use these tools,' " says MacLean.
The bank is having open discussions
around generative AI and is focusing
on educating and teaching teams how
to use these tools safely.
The two primary risks of
generative AI in banking
There are two major downside risks
to generative AI: data privacy and bad
actors using AI in fraud and cyber
attacks. Bharwani advises community
banks to look at each category
separately and implement strategies
around those risks.
On the data privacy side, many
organizations are simply blocking
ChatGPT. However, there is nothing
preventing a bank employee from
going to their personal device and
putting information about the bank
into the chat to get answers.
Instead of blocking generative AI
altogether, community banks should
consider developing a framework
to create more visibility around its
use, which is where AI governance
and data management policies come
into play.
" It really starts with the policies, "
Bharwani says. " What are the policies
regarding our employees on how
they should and should not leverage
these systems? "
Bharwani advises that clients set up
accounts for employees on generative
AI so that they are better able to
monitor that use. He notes that
redaction capabilities and information
rights controls are becoming more
common. Another step is to hold staff
training sessions that make people
aware of the policies around how they
can and can't use these tools.
Although there is a lot of
excitement around the potential of
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Independent Banker - September 2023

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