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NEURAL
NETWORKS
TheNextStepforArtificialIntelligence
inFinancialServices
A perspective from Financial Services Technology Advisory
2 NEURAL NETWORKS
EXECUTIVESUMMARY
The adoption of artificial
intelligence (AI) across
the financial services
industry is advancing at
an unprecedented pace.
As firms strive to transform their businesses
for a digital world, realize efficiencies, improve
the customer experience and revitalize their
growth, they increasingly see AI and machine
learning as vital enablers—and are investing
in understanding how they can leverage them
to greatest effect.
As machine learning becomes mainstream,
the next wave of AI innovation in financial
services is already emerging: artificial neural
networks. Based on the multi-layered neuron
structures that mimic the human brain, neural
networks offer a step-change in the power of
AI, opening up opportunities to automate ever
more complex processes and decisions with
the highest possible degree of accuracy.
Early AI proofs of concept (PoCs) involving
neural networks implemented by financial
services firms have yielded promising results.
But while their potential is significant, they
should be approached with care. Initially
developed in academia, neural networks
were designed to deliver the highest possible
accuracy with little focus on explainability.
However, in regulated sectors like banking and
insurance, where both regulators and customers
often ask to know why a particular decision
was made, an inability to explain AI reasoning
can expose firms to risks ranging from legal
challenges to a loss of customer trust.
The good news is that these risks can be
addressed, and that—alongside neural networks
—there are multiple machine learning options
available. As a result, financial services firms
can effectively harness the power of machine
learning to solve some of the most complex
problems they face. To do this, firms have to
put in place appropriate processes, practices,
tools and controls to make responsible and
ethical use of these extremely effective
capabilities and apply appropriate algorithms
to the right processes in the appropriate way.
In this paper, we map out the various
components and steps for an effective
implementation of neural networks—the next
stage of financial services’ AI journey.
3 NEURAL NETWORKS
CONTEXT:THEEVOLVING
LANDSCAPEOFAIIN
FINANCIALSERVICES
AI has come of age for
financial services firms...
Across the global financial services industry,
interest in the potential of AI is growing
by the day. Organizations are eager to
automate a growing range of processes
across their operations, with a view to gaining
several tangible business benefits—including
lower costs, higher accuracy, an improved
customer experience, and ultimately
business transformation and competitive edge.
In search of these benefits, financial services
firms have progressed in recent years from
advanced statistical modeling to more complex
algorithms and AI techniques, including
combining robotic process automation (RPA)
with cognitive AI technologies. To date, the
industry’s focus has been mainly on a major
subset of AI: machine learning algorithms.
These are a form of AI that can learn and improve
automatically on the basis of experience—
qualities that are well-suited to many types
of decision-making in financial services.
AI in financial services:
A rising tide of innovation
—and savings
The momentum behind AI in financial
services is now unstoppable. A recent
survey by Intertrust Group B.V.1
of 500
senior financial services decision-makers’
views on disruptive technologies found
that 77% think AI will play the biggest role
in revolutionizing the industry over the
coming five years, ahead of blockchain
(56%) and robotics (27%). And financial
services research house Autonomous
Research LLP2
estimates that financial
services firms can expect AI to help
reduce their operating expenses by
about 20%, resulting in savings totaling
US$1 trillion globally by 2030. Meanwhile,
Accenture’s own research3
suggests that
AI will add US$1.153 billion in value to
the financial services industry by 2035.
4 NEURAL NETWORKS
...and neural networks are
emerging as the next step
Having advanced from AI in general to machine
learning, the industry’s focus is now evolving
further—to a specific subset of machine learning
called neural networks. As the accompanying
information panel explains, neural networks
are highly complex machine learning algorithms
that are structured as a number of interconnected
layers of neurons. As well as reasoning taking
place within each layer, the neurons within the
different layers also interact and affect each
other, creating a hugely powerful model for
complex decision-making. The effect is that
neural networks work in a way analogous to
3D, while simpler AI reasoning is more like 2D.
This makes neural networks especially suited
to complex “deep learning” applications
that require the processing of massive amounts
of data and high levels of domain expertise
and judgment.
The power and wide applicability of neural
networks and deep learning are seeing these
technologies gain usage in financial services.
This ongoing increase reflects factors including
the availability of massive amounts of data
(both internal and from third parties), ongoing
academic advances, and algorithmic innovation
supported by expanding computing power,
especially on cloud platforms. These drivers have
been supplemented by high-profile marketing
and communications efforts from the global
technology giants, further boosting awareness
of AI and of neural networks in particular.
What are neural networks?
Artificial neural networks are inspired
by the structure of the human brain.
A typical neural network is made up
of millions of artificial neurons arranged
in a series of connected layers. During
training of the model, the first layer serves
as an example of input variables—such
as documents, number or pixels from
images—from which the model learns
to create an association, with the output
in the final layer, representing the target
outcome. The ‘”hidden” layers in between
the input and output layer convey the
logic connecting the input to the output,
cresting a network of reasoning that is
much more complex than a relatively
simpler linear algorithm.
5 NEURAL NETWORKS
ABROADRANGEOFUSECASES
The attributes of neural
networks—particularly
their ability to handle highly
complex decisions—makes
them ideally suited to
a wide variety of use cases
in financial services.
Table 1: Sample use cases for neural network in financial services
Unlocking Value Prediction Unlocking Unstructured Data Unlocking Imagery
Banking •	Fraud detection for
credit card transactions
•	Overdraft predictions
based on the customer’s
transaction history
•	Information retrieval from
invoices to substantiate
a transaction on business
accounts
•	Verification of the plausibility
of property prices from
mortgage application by
performing internet searches
•	Using a facial recognition
system to log into applications
for corporate banking
(already introduced by
HSBC Holdings plc)4
•	Using satellite and street view
images to verify the existence
of a business as a part of know
your customer (KYC) and anti-
money laundering (AML) checks
Insurance •	By collecting and processing
data from wearable devices,
insurance companies can
use neural networks to predict
health problems and suggest
lifestyle changes
•	Analyzing customers’
interactions with the company
to offer discounts to customers
who wish to leave
•	Accident severity evaluations
based on the description in
the claim
•	Assessing the level and
type of risk associated with
a customer based on their
social media activity
•	Car accident damage
assessment
•	Risk prediction for home
insurance based on images of
the building and surrounding
objects such as trees and rivers
Capital
Markets
•	Helping traders decide what
price to quote when buying
or selling bonds for their
clients based on historic
and real market data
•	Using electronic routing
algorithms to find a match from
stock brokers, stock exchanges
or alternative trading systems
that can fulfill the order
•	Extracting information
regarding profit or losses
from financial reports to aid
investment decision-making
•	Information extraction and
summarization of legal
documents
•	Automation of site
and due diligence checks
Source: Accenture, July 2019
The table below provides a snapshot
of some of the common applications
for neural networks in different sectors
of the industry, across the three areas of
predicting future value, extracting meaning
from unstructured data such as language,
and recognizing objects on images.
6 NEURAL NETWORKS
ASSESSINGTHEPROSAND
CONSOFNEURALNETWORKS
Energized by the potential value created
by this powerful technology, and the
pressures to increase automated processes
and meet aggressive accuracy targets,
we are seeing more and more financial
services firms piloting—or already deploying
—neural networks. However, while the results
are often promising, there are a number
of pitfalls that firms should be aware of
before pressing ahead with implementing
neural networks in live production.
Neural networks’ focus
on accuracy rather than
explainability...
Foremost among the possible challenges
is the need for the decisions made by neural
networks to be explainable. In highly regulated
sectors such as retail banking and insurance,
the industry’s regulators—and indeed its
customers—often ask to understand why
a particular decision was made. And as AI
decisions come to affect people’s lives ever
more profoundly, for example through the
refusal of a loan, credit card or insurance cover,
the demand for explainability and transparency
around reasoning is expected to only increase.
However, despite billions of dollars of
investment in the field of AI explainability,5
AI models today mostly remain “black-box”
solutions with no native way of articulating the
reasoning behind their decisions. Accenture
Labs has published a paper outlining the key
requirements for making AI explainable6
Some key considerations
with neural networks
EXPLAINABILITY
This term refers to the ability of the
algorithm to justify its decisions. While
explainability is relatively transparent
with simpler linear algorithms, the more
complex and layered nature of neural
networks make them a more opaque
“black box” form of AI.
ACCURACY
This defines how correct the model
should be—typically driven by business
requirements and model capabilities.
DATA INSTANCES FOR TRAINING
Training different algorithms requires
different amounts of data. Linear models
can be trained reasonably well on a
relatively small number of observations,
and neural networks’ complexity means
they need far more instances to learn from.
DEVELOPMENT TIME
The need for a large number of parameters
when training neural networks means
their development time is typically
longer than with simpler AI models.
—and in it, the authors stress that the full
promise of AI systems won’t be realized unless
people can understand the recommendations
they make (see panel).
7 NEURAL NETWORKS
Why has explainability not made greater
progress in neural networks? The fact that
they were originally created by the academic
community means the core goal guiding
their development was not explainability
or algorithmic transparency, but the highest
possible accuracy. So neural networks were
not originally designed to answer explainability
questions. And while they have been shown
to solve remarkably difficult tasks, concerns
remain over their high complexity and limited
transparency – reflecting low awareness and
understanding of how the neurons interact
within multi-layered neural networks to arrive
at a certain prediction.
...creates a number
of additional concerns
A further barrier to explainability with neural
networks is their complexity. Simpler models
can reveal relatively easily why—for example
—a customer has failed a KYC check, allowing
a human investigator to validate the accuracy
of the judgment and make the final call.
The complexity of neural networks’ reasoning
makes this more challenging.
Beyond the issues around explainability,
neural networks’ underlying focus on
accuracy rather than transparency can give
rise to a number of other concerns. One of
the main worries is that it may be difficult to
spot bias that could manifest itself through
discriminatory outcomes in the long term.
This might lead to unfair treatment of certain
groups of customers, and potentially legal
action for alleged discrimination.
Going forward, AI promises
to help us identify dangerous
industrial sites, warn us
of impending machine
failures, recommend
medical treatments, and take
countless other decisions.
But the promise of these
systems won’t be realized
unless we can understand,
trust and act on the
recommendations they
make. To make this possible,
high-quality explanations
will be essential.
Source: Understanding Machines:
Explainable AI. Accenture 2018.
8 NEURAL NETWORKS
Firms should consider
the available data and
infrastructure...
There are two other areas that firms considering
implementing neural networks should examine
carefully. One is that the data used for training
these models is of sufficient quality, scale and
diversity. While a simple algorithm might be
adequately trained using less than a hundred
data instances, with a neural network the
number is likely to run into tens of thousands
or even millions. Otherwise, once in live
production, the system may either make
some decisions with low confidence or
return completely unpredictable results.
The other area to consider is IT infrastructure.
Neural networks require vast amounts of
processing power, and often the only way
of accessing sufficient capacity is by tapping
into the cloud.
...and how to build trust
among stakeholders
Finally, as with any emerging technology,
trust and confidence among stakeholders
is key to neural networks’ long-term use.
But the concerns over explainability,
algorithmic transparency and bias can all
put this trust under threat. While any gaps
in computing power or data can be noticeable
almost immediately, explainability issues
may become apparent only at the later stages,
often after the models have been fully built.
This can delay go-live dates and create mistrust
and skepticism around AI among end users.
Source: Accenture, July 2019
9 NEURAL NETWORKS
Table 2: A comparison of different AI algorithms and their requirements7
Data Requirements Explainability Accuracy Processing Power
Linear regression
Logistic regression
Naïve Bayes
Support vector
machines
Decision trees
Random forest
k-means
Neural networks
Ensemble learning
While enhancing the accuracy of neural
networks is an important target to aim for,
we would recommend that firms also focus
on other performance objectives and consider
alternative algorithms as part of their AI suite.
DIVERSEPERFORMANCE
OBJECTIVESANDALGORITHMS
Some examples of these algorithms are
shown in the table below, complete with
their respective requirements in terms of data,
explainability, accuracy and processing power.
10 NEURAL NETWORKS
FROM“BLACKBOX”
TO“GLASSBOX”
Start with the process
to be automated—not the
technology...
For any firm considering implementing AI to
automate a process, the first step should be
to focus not on the technology, but the specific
process to be automated. By evaluating,
identifying and quantifying the level of need
to explain the model’s decisions in the process—
and the related risks in areas such as bias—the
business can define explainability upfront as an
overarching business requirement, and balance
it with the goal of enhancing the accuracy of
the model. This opens the way for developers
to build in explainability from the beginning,
allowing the neural network model to become
a “glass box” rather than a “black box”.
To support this approach, firms should create
ethical guiderails that broadly define the use
cases for which neural networks—and AI more
generally— should and should not be used.
As a rule of thumb, neural networks are more
suitable for the processes where accuracy
is more important than explainability, and the
impact of incorrect decisions on people’s lives
and firms’ reputation and financial stability
is relatively low. However, as explainability
improves in years to come, usage of neural
network may expand into more areas.
...and apply ethics
as a matter of policy
It’s significant that world-leading AI pioneers
such as Google LLC8
and Microsoft Corporation9
already have ethical frameworks in place
regulating their AI use cases. In Accenture’s
view, financial services firms should learn from
their example by imposing ethical criteria and
requirements that reflect their own values
and address wider legislation for algorithmic
transparency at a policy level. And at an
operational level, these criteria should be
made a part of every opportunity qualification
framework—along with technical readiness
and business benefits—during the process
assessment and algorithm selection processes.
Figure 1: A process assessment
Source: Accenture, July 2019
Where are you at?
Risk
Other
algorithms
Neural
networks
Explanation
Accuracy
11 NEURAL NETWORKS
Trading-off explainability
and accuracy
That said, explainability and accuracy can
sometimes be traded off against each other
(see Figure 1)—and there are certain processes
and scenarios where explainability becomes
“good to have” rather than “must have”.
These are scenarios where the problem is
well understood, and the recommendation can
be approximated and verified with alternative
techniques, or alternatively where there is
a human agent in the loop, who is competent
and authorized to validate and override the
decision made by AI. These are the cases
where the risk is relatively low, and accuracy
more important than reasoning—with bank
product suggestions being one example.
Finally, there are some processes where the
system’s decision might be misinterpreted
or misused by end users. For example, staff in
bank branches might notice that it is easier for
customers to have their mortgage application
approved if they do not currently have any
outstanding loans. As a result, they might
advise a customer who wishes to get both
a mortgage and a loan to apply for the
mortgage first—as the mortgage application
is the more stringent process, while the loan
is more straightforward and easier to get
approved. If staff did behave this way, it could
result in a higher risk of defaults on mortgage
payment in the future.
As this scenario underlines, it is important to
think carefully when defining the level of detail
in the explanation of an AI decision, and the
list of users to whom the explanation should be
displayed. Figure 2 illustrates the spectrum of
use cases for which neural networks generally
should not be used, and those for which they
should only be used in combination with strict
controls and governance.
Figure 2: Use cases for which neural networks can be used with due consideration
Source: Accenture, July 2019
SHOULD NOT BE USED STRICT CONTROLS AND GOVERNANCE SHOULD BE IN PLACE
Can have a
profound impact
on human lives
Can cause
physical damages
to properties
or vehicles
The decision has
to be explained
to customers,
staff or regulators
Regulatory process
or process spans
several jurisdictions
Model relies on sensitive
data and protected
characteristics, or features
strongly correlated to them
12 NEURAL NETWORKS
SIXSTEPSTOTHEEFFECTIVE
IMPLEMENTATIONOF
NEURALNETWORKS
As we’ve highlighted in this
paper, for firms to select,
develop and implement
neural network algorithms
that are not only effective
and accurate but also
compliant, we believe they
should first put in place the
appropriate IT infrastructure
with sufficient processing
power—generally from the
cloud—and then overlay
this with a robust set
of frameworks, controls,
tools and ethical principles.
Building on these solid foundations, here are
six steps for an effective implementation.
1. Have your training data ready
Adequate training of neural networks requires
far more data instances than simpler, linear AI
models. To avoid problems with insufficient
training, potential issues over data quality and
volume should be addressed at various levels
in the organization. At an enterprise level, the
Chief Data Officer (CDO) should provide a data
lake that is curated and appropriately governed,
striking a balance between providing greater
insight and value while providing compliance
with data protection regulations.10
Also, all
source data for training should adhere to the
three data-focused tenets: provenance (the
history of the data throughout its lifecycle);
context (the circumstances around data use);
and integrity (data security and maintenance).11
During exploratory data analysis, the team
of data scientists should consider not only the
volume of available data, but also how diverse
the sample is, whether all groups of customers
are equally represented, and whether the
human agents in any training scenarios
made decisions that were fair to all customers.
Focusing on these issues can allow the data
scientists to apply appropriate data treatment
strategies to reduce any embedded bias in the
data, while also providing enhanced coverage
(the model’s ability to make decisions)
and accuracy (the model’s ability to make
correct decisions).
13 NEURAL NETWORKS
Brakes help a car go faster.12
2. Change your culture
Bias can creep into a neural network not
only through the training data, but also at
the fine-tuning stage. For example, the model
developer might discover that manually
increasing the weighting attributed to certain
factors can lead to more accurate results
—but this might have an unintended negative
impact on fairness. So it is important to
change the culture of the data science teams
by providing them with ethical and anti-
discriminatory training, thereby increasing
their awareness of protective characteristics,
bias and ethicality. Leaders should also look
to create diverse teams of data scientists
and promote collaboration and peer reviews.
3. Keep experimenting
When building a model, the data scientists
should compare several algorithms and keep
experimenting with them to evaluate their
relative levels of suitability for the task at hand.
In doing this, they should bear in mind that
a neural network may not be the best choice
for use cases where training data is scarce
and where more transparent algorithms
could play the same role.
4. Test and validate
In addition to standard machine learning
testing on 20% of the “holdout sample” or
validation set, it is also advisable to conduct
cross-validation, since this can reveal a model’s
ability to generalize—which means making
decisions on previously unseen cases.
To allow this, the data sample used should
be carefully selected to represent both
frequently occurring scenarios and also
boundary or “outlier” conditions. In applications
such as fraud detection, where the amount
of “live” fraudulent data is usually much smaller
than non-fraudulent transactions, anomalous
transactions should be deliberately selected
or created for testing purposes. Finally, fairness
testing should be carried out to complement
the technical tests, and make sure that the
model does not discriminate against or favor
certain groups of customers.
5. Keep on top of documentation
Each step of the model design process
should be recorded, and the documentation
about each model maintained and updated
continuously throughout its entire lifecycle.
The documentation should also be strictly
governed while being made accessible to
all relevant and authorized stakeholders.
6. Create a center of excellence
for responsible AI
To attain and sustain leadership in the use
of neural networks, each financial services firm
should set up a dedicated function to act as
a center of excellence in the responsible use
of AI, including neural networks. This central
resource would establish preferred practices
and standards, drive AI-focused thought
leadership and research, and impose risk
controls and governance so all use of AI across
the organization is ethical and compliant.
Dr. Rumman Chowdhury, Accenture Labs
14 NEURAL NETWORKS
WHATNEXT?
Effectively implementing
a neural network is not the
end of the story. As any
AI model operates, learns
and makes decisions, the
world around it continues to
change, and its performance
may degrade over time.
All of this means that controls and quality
assurance should not stop after deployment
but should be maintained and reviewed
throughout the model’s entire lifecycle.
Ongoing considerations include the following.
Regulatory changes: Continuous monitoring
of the regulatory environment is critical, both
with respect to automated processes (such
as changes in trade or AML laws) and AI legal
requirements (such as explainability obligations
or data handling restrictions).
Accuracy and bias monitoring: Ongoing
monitoring of accuracy and bias has to be
maintained, to allow the neural network’s
performance not to drop below defined
thresholds and that its decisions do not
systematically favor certain groups.
Security and re-training data screening:
Maintaining strict cyber security provisioning
is vitally important. Also, as firms re-train their
models to keep pace with changes in the
wider environment, they should take account
of the risk that “poisoning” training data with
adversarial examples can skew neural networks’
reasoning, resulting in the models taking
decisions that are incorrect and potentially
illegal. And malicious access to the model
itself—whether from inside or outside the firm
—can compromise competitive advantage,
and even lead to criminal misuse of the model,
such as playing on stock market predictions.
Quality assurance and audit: Many financial
firms have already established a framework
for traditional model validation, and in many
cases have been using this for years. However,
while this framework might be adequate for
relatively simple models, firms should consider
introducing adjustments and refinements
to accommodate the higher complexity
and ambiguity of neural networks and deep
learning models.
Plan B: There should always be a back-up
model that the system can turn to automatically,
in the event that the front-line model displays
signs of degradation.
15 NEURAL NETWORKS
CONCLUSION:APOWERFUL
TOOL—TOBEUSEDWITHCARE
There’s no doubt that
neural networks are a
powerful tool for financial
services firms as they seek
to improve efficiency,
enhance the accuracy of
their decision-making, boost
revenues and improve the
experience for customers.
But like any other powerful tool, neural
networks should be used with due care and
consideration—and in the light of the fullest
possible information.
Authors
Additional contacts
Sabyasachi (Saby) Roy
Managing Director
Financial Services Technology Advisory
Artificial Intelligence Lead UKI
sabyasachi.a.roy@accenture.com
Elena Khmeleva, PhD
Technology Consultant
Financial Services Technology Advisory
Intelligent Automation UKI
elena.khmeleva@accenture.com
Elodie B. de Fontenay
Director
Financial Services Technology Advisory
Offering Development Global
elodie.b.de.fontenay@accenture.com
David C. Jones
Managing Director
Financial Services Technology Advisory
Intelligent Automation Global
david.c.jones@accenture.com
Tim Broome
Managing Director
Financial Services Technology Advisory
Intelligent Automation APAC
tim.broome@accenture.com
About Accenture
Accenture is a leading global professional
services company, providing a broad range of
services and solutions in strategy, consulting,
digital, technology and operations. Combining
unmatched experience and specialized skills
across more than 40 industries and all business
functions—underpinned by the world’s largest
delivery network—Accenture works at the
intersection of business and technology to help
clients improve their performance and create
sustainable value for their stakeholders. With
more than 482,000 people serving clients in
more than 120 countries, Accenture drives
innovation to improve the way the world works
and lives. Its home page is www.accenture.com
References
1	 “Global financial services industry bullish towards
disruptive technology but widescale adoption yet
to come,” Intertrust, November 28, 2018.
2	 “#Augmented Finance & Machine Intelligence,”
Autonomous Next, April 2018.
3	 “How AI Boosts Industry Profits and Innovation,”
Accenture, 2017.
4	 “HSBC rolls out facial recognition for mobile,”
Financial Times, May 8, 2018.
5	 “DARPA Plans To Spend $2 Billion Developing New AI
Technologies,” Forbes, September 7, 2018.
6	 “Understanding Machines: Explainable AI,” Accenture 2018.
7	 “Machine learning algorithm cheat sheet for Azure Machine
Learning Studio,” Microsoft, March 3, 2019.
8	 “Responsible AI Practices,” Google, 2019.
9	 “Our approach: Microsoft AI principles,” Microsoft, 2019.
10	“What’s Your Data Strategy?,” Harvard Business Review,
June 2017.
11	 “Redefine Your Company Based on the Company You
Keep,” Accenture, 2018.
12	 Accenture Labs, March 11, 2019.
Disclaimer: This document is intended for general
informational purposes only and does not take into account
the reader’s specific circumstances, and may not reflect
the most current developments. Accenture disclaims, to
the fullest extent permitted by applicable law, any and
all liability for the accuracy and completeness of the
information in this document and for any acts or omissions
made based on such information. Accenture does not
provide legal, regulatory, audit, or tax advice. Readers are
responsible for obtaining such advice from their own legal
counsel or other licensed professionals.
Copyright © 2019 Accenture.
All rights reserved.
Accenture and its logo are trademarks of Accenture. 191109
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www.accenture.com/us-en/services/financial-
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The Next Step For Aritificial Intelligence in Financial Services

  • 2. 2 NEURAL NETWORKS EXECUTIVESUMMARY The adoption of artificial intelligence (AI) across the financial services industry is advancing at an unprecedented pace. As firms strive to transform their businesses for a digital world, realize efficiencies, improve the customer experience and revitalize their growth, they increasingly see AI and machine learning as vital enablers—and are investing in understanding how they can leverage them to greatest effect. As machine learning becomes mainstream, the next wave of AI innovation in financial services is already emerging: artificial neural networks. Based on the multi-layered neuron structures that mimic the human brain, neural networks offer a step-change in the power of AI, opening up opportunities to automate ever more complex processes and decisions with the highest possible degree of accuracy. Early AI proofs of concept (PoCs) involving neural networks implemented by financial services firms have yielded promising results. But while their potential is significant, they should be approached with care. Initially developed in academia, neural networks were designed to deliver the highest possible accuracy with little focus on explainability. However, in regulated sectors like banking and insurance, where both regulators and customers often ask to know why a particular decision was made, an inability to explain AI reasoning can expose firms to risks ranging from legal challenges to a loss of customer trust. The good news is that these risks can be addressed, and that—alongside neural networks —there are multiple machine learning options available. As a result, financial services firms can effectively harness the power of machine learning to solve some of the most complex problems they face. To do this, firms have to put in place appropriate processes, practices, tools and controls to make responsible and ethical use of these extremely effective capabilities and apply appropriate algorithms to the right processes in the appropriate way. In this paper, we map out the various components and steps for an effective implementation of neural networks—the next stage of financial services’ AI journey.
  • 3. 3 NEURAL NETWORKS CONTEXT:THEEVOLVING LANDSCAPEOFAIIN FINANCIALSERVICES AI has come of age for financial services firms... Across the global financial services industry, interest in the potential of AI is growing by the day. Organizations are eager to automate a growing range of processes across their operations, with a view to gaining several tangible business benefits—including lower costs, higher accuracy, an improved customer experience, and ultimately business transformation and competitive edge. In search of these benefits, financial services firms have progressed in recent years from advanced statistical modeling to more complex algorithms and AI techniques, including combining robotic process automation (RPA) with cognitive AI technologies. To date, the industry’s focus has been mainly on a major subset of AI: machine learning algorithms. These are a form of AI that can learn and improve automatically on the basis of experience— qualities that are well-suited to many types of decision-making in financial services. AI in financial services: A rising tide of innovation —and savings The momentum behind AI in financial services is now unstoppable. A recent survey by Intertrust Group B.V.1 of 500 senior financial services decision-makers’ views on disruptive technologies found that 77% think AI will play the biggest role in revolutionizing the industry over the coming five years, ahead of blockchain (56%) and robotics (27%). And financial services research house Autonomous Research LLP2 estimates that financial services firms can expect AI to help reduce their operating expenses by about 20%, resulting in savings totaling US$1 trillion globally by 2030. Meanwhile, Accenture’s own research3 suggests that AI will add US$1.153 billion in value to the financial services industry by 2035.
  • 4. 4 NEURAL NETWORKS ...and neural networks are emerging as the next step Having advanced from AI in general to machine learning, the industry’s focus is now evolving further—to a specific subset of machine learning called neural networks. As the accompanying information panel explains, neural networks are highly complex machine learning algorithms that are structured as a number of interconnected layers of neurons. As well as reasoning taking place within each layer, the neurons within the different layers also interact and affect each other, creating a hugely powerful model for complex decision-making. The effect is that neural networks work in a way analogous to 3D, while simpler AI reasoning is more like 2D. This makes neural networks especially suited to complex “deep learning” applications that require the processing of massive amounts of data and high levels of domain expertise and judgment. The power and wide applicability of neural networks and deep learning are seeing these technologies gain usage in financial services. This ongoing increase reflects factors including the availability of massive amounts of data (both internal and from third parties), ongoing academic advances, and algorithmic innovation supported by expanding computing power, especially on cloud platforms. These drivers have been supplemented by high-profile marketing and communications efforts from the global technology giants, further boosting awareness of AI and of neural networks in particular. What are neural networks? Artificial neural networks are inspired by the structure of the human brain. A typical neural network is made up of millions of artificial neurons arranged in a series of connected layers. During training of the model, the first layer serves as an example of input variables—such as documents, number or pixels from images—from which the model learns to create an association, with the output in the final layer, representing the target outcome. The ‘”hidden” layers in between the input and output layer convey the logic connecting the input to the output, cresting a network of reasoning that is much more complex than a relatively simpler linear algorithm.
  • 5. 5 NEURAL NETWORKS ABROADRANGEOFUSECASES The attributes of neural networks—particularly their ability to handle highly complex decisions—makes them ideally suited to a wide variety of use cases in financial services. Table 1: Sample use cases for neural network in financial services Unlocking Value Prediction Unlocking Unstructured Data Unlocking Imagery Banking • Fraud detection for credit card transactions • Overdraft predictions based on the customer’s transaction history • Information retrieval from invoices to substantiate a transaction on business accounts • Verification of the plausibility of property prices from mortgage application by performing internet searches • Using a facial recognition system to log into applications for corporate banking (already introduced by HSBC Holdings plc)4 • Using satellite and street view images to verify the existence of a business as a part of know your customer (KYC) and anti- money laundering (AML) checks Insurance • By collecting and processing data from wearable devices, insurance companies can use neural networks to predict health problems and suggest lifestyle changes • Analyzing customers’ interactions with the company to offer discounts to customers who wish to leave • Accident severity evaluations based on the description in the claim • Assessing the level and type of risk associated with a customer based on their social media activity • Car accident damage assessment • Risk prediction for home insurance based on images of the building and surrounding objects such as trees and rivers Capital Markets • Helping traders decide what price to quote when buying or selling bonds for their clients based on historic and real market data • Using electronic routing algorithms to find a match from stock brokers, stock exchanges or alternative trading systems that can fulfill the order • Extracting information regarding profit or losses from financial reports to aid investment decision-making • Information extraction and summarization of legal documents • Automation of site and due diligence checks Source: Accenture, July 2019 The table below provides a snapshot of some of the common applications for neural networks in different sectors of the industry, across the three areas of predicting future value, extracting meaning from unstructured data such as language, and recognizing objects on images.
  • 6. 6 NEURAL NETWORKS ASSESSINGTHEPROSAND CONSOFNEURALNETWORKS Energized by the potential value created by this powerful technology, and the pressures to increase automated processes and meet aggressive accuracy targets, we are seeing more and more financial services firms piloting—or already deploying —neural networks. However, while the results are often promising, there are a number of pitfalls that firms should be aware of before pressing ahead with implementing neural networks in live production. Neural networks’ focus on accuracy rather than explainability... Foremost among the possible challenges is the need for the decisions made by neural networks to be explainable. In highly regulated sectors such as retail banking and insurance, the industry’s regulators—and indeed its customers—often ask to understand why a particular decision was made. And as AI decisions come to affect people’s lives ever more profoundly, for example through the refusal of a loan, credit card or insurance cover, the demand for explainability and transparency around reasoning is expected to only increase. However, despite billions of dollars of investment in the field of AI explainability,5 AI models today mostly remain “black-box” solutions with no native way of articulating the reasoning behind their decisions. Accenture Labs has published a paper outlining the key requirements for making AI explainable6 Some key considerations with neural networks EXPLAINABILITY This term refers to the ability of the algorithm to justify its decisions. While explainability is relatively transparent with simpler linear algorithms, the more complex and layered nature of neural networks make them a more opaque “black box” form of AI. ACCURACY This defines how correct the model should be—typically driven by business requirements and model capabilities. DATA INSTANCES FOR TRAINING Training different algorithms requires different amounts of data. Linear models can be trained reasonably well on a relatively small number of observations, and neural networks’ complexity means they need far more instances to learn from. DEVELOPMENT TIME The need for a large number of parameters when training neural networks means their development time is typically longer than with simpler AI models. —and in it, the authors stress that the full promise of AI systems won’t be realized unless people can understand the recommendations they make (see panel).
  • 7. 7 NEURAL NETWORKS Why has explainability not made greater progress in neural networks? The fact that they were originally created by the academic community means the core goal guiding their development was not explainability or algorithmic transparency, but the highest possible accuracy. So neural networks were not originally designed to answer explainability questions. And while they have been shown to solve remarkably difficult tasks, concerns remain over their high complexity and limited transparency – reflecting low awareness and understanding of how the neurons interact within multi-layered neural networks to arrive at a certain prediction. ...creates a number of additional concerns A further barrier to explainability with neural networks is their complexity. Simpler models can reveal relatively easily why—for example —a customer has failed a KYC check, allowing a human investigator to validate the accuracy of the judgment and make the final call. The complexity of neural networks’ reasoning makes this more challenging. Beyond the issues around explainability, neural networks’ underlying focus on accuracy rather than transparency can give rise to a number of other concerns. One of the main worries is that it may be difficult to spot bias that could manifest itself through discriminatory outcomes in the long term. This might lead to unfair treatment of certain groups of customers, and potentially legal action for alleged discrimination. Going forward, AI promises to help us identify dangerous industrial sites, warn us of impending machine failures, recommend medical treatments, and take countless other decisions. But the promise of these systems won’t be realized unless we can understand, trust and act on the recommendations they make. To make this possible, high-quality explanations will be essential. Source: Understanding Machines: Explainable AI. Accenture 2018.
  • 8. 8 NEURAL NETWORKS Firms should consider the available data and infrastructure... There are two other areas that firms considering implementing neural networks should examine carefully. One is that the data used for training these models is of sufficient quality, scale and diversity. While a simple algorithm might be adequately trained using less than a hundred data instances, with a neural network the number is likely to run into tens of thousands or even millions. Otherwise, once in live production, the system may either make some decisions with low confidence or return completely unpredictable results. The other area to consider is IT infrastructure. Neural networks require vast amounts of processing power, and often the only way of accessing sufficient capacity is by tapping into the cloud. ...and how to build trust among stakeholders Finally, as with any emerging technology, trust and confidence among stakeholders is key to neural networks’ long-term use. But the concerns over explainability, algorithmic transparency and bias can all put this trust under threat. While any gaps in computing power or data can be noticeable almost immediately, explainability issues may become apparent only at the later stages, often after the models have been fully built. This can delay go-live dates and create mistrust and skepticism around AI among end users.
  • 9. Source: Accenture, July 2019 9 NEURAL NETWORKS Table 2: A comparison of different AI algorithms and their requirements7 Data Requirements Explainability Accuracy Processing Power Linear regression Logistic regression Naïve Bayes Support vector machines Decision trees Random forest k-means Neural networks Ensemble learning While enhancing the accuracy of neural networks is an important target to aim for, we would recommend that firms also focus on other performance objectives and consider alternative algorithms as part of their AI suite. DIVERSEPERFORMANCE OBJECTIVESANDALGORITHMS Some examples of these algorithms are shown in the table below, complete with their respective requirements in terms of data, explainability, accuracy and processing power.
  • 10. 10 NEURAL NETWORKS FROM“BLACKBOX” TO“GLASSBOX” Start with the process to be automated—not the technology... For any firm considering implementing AI to automate a process, the first step should be to focus not on the technology, but the specific process to be automated. By evaluating, identifying and quantifying the level of need to explain the model’s decisions in the process— and the related risks in areas such as bias—the business can define explainability upfront as an overarching business requirement, and balance it with the goal of enhancing the accuracy of the model. This opens the way for developers to build in explainability from the beginning, allowing the neural network model to become a “glass box” rather than a “black box”. To support this approach, firms should create ethical guiderails that broadly define the use cases for which neural networks—and AI more generally— should and should not be used. As a rule of thumb, neural networks are more suitable for the processes where accuracy is more important than explainability, and the impact of incorrect decisions on people’s lives and firms’ reputation and financial stability is relatively low. However, as explainability improves in years to come, usage of neural network may expand into more areas. ...and apply ethics as a matter of policy It’s significant that world-leading AI pioneers such as Google LLC8 and Microsoft Corporation9 already have ethical frameworks in place regulating their AI use cases. In Accenture’s view, financial services firms should learn from their example by imposing ethical criteria and requirements that reflect their own values and address wider legislation for algorithmic transparency at a policy level. And at an operational level, these criteria should be made a part of every opportunity qualification framework—along with technical readiness and business benefits—during the process assessment and algorithm selection processes. Figure 1: A process assessment Source: Accenture, July 2019 Where are you at? Risk Other algorithms Neural networks Explanation Accuracy
  • 11. 11 NEURAL NETWORKS Trading-off explainability and accuracy That said, explainability and accuracy can sometimes be traded off against each other (see Figure 1)—and there are certain processes and scenarios where explainability becomes “good to have” rather than “must have”. These are scenarios where the problem is well understood, and the recommendation can be approximated and verified with alternative techniques, or alternatively where there is a human agent in the loop, who is competent and authorized to validate and override the decision made by AI. These are the cases where the risk is relatively low, and accuracy more important than reasoning—with bank product suggestions being one example. Finally, there are some processes where the system’s decision might be misinterpreted or misused by end users. For example, staff in bank branches might notice that it is easier for customers to have their mortgage application approved if they do not currently have any outstanding loans. As a result, they might advise a customer who wishes to get both a mortgage and a loan to apply for the mortgage first—as the mortgage application is the more stringent process, while the loan is more straightforward and easier to get approved. If staff did behave this way, it could result in a higher risk of defaults on mortgage payment in the future. As this scenario underlines, it is important to think carefully when defining the level of detail in the explanation of an AI decision, and the list of users to whom the explanation should be displayed. Figure 2 illustrates the spectrum of use cases for which neural networks generally should not be used, and those for which they should only be used in combination with strict controls and governance. Figure 2: Use cases for which neural networks can be used with due consideration Source: Accenture, July 2019 SHOULD NOT BE USED STRICT CONTROLS AND GOVERNANCE SHOULD BE IN PLACE Can have a profound impact on human lives Can cause physical damages to properties or vehicles The decision has to be explained to customers, staff or regulators Regulatory process or process spans several jurisdictions Model relies on sensitive data and protected characteristics, or features strongly correlated to them
  • 12. 12 NEURAL NETWORKS SIXSTEPSTOTHEEFFECTIVE IMPLEMENTATIONOF NEURALNETWORKS As we’ve highlighted in this paper, for firms to select, develop and implement neural network algorithms that are not only effective and accurate but also compliant, we believe they should first put in place the appropriate IT infrastructure with sufficient processing power—generally from the cloud—and then overlay this with a robust set of frameworks, controls, tools and ethical principles. Building on these solid foundations, here are six steps for an effective implementation. 1. Have your training data ready Adequate training of neural networks requires far more data instances than simpler, linear AI models. To avoid problems with insufficient training, potential issues over data quality and volume should be addressed at various levels in the organization. At an enterprise level, the Chief Data Officer (CDO) should provide a data lake that is curated and appropriately governed, striking a balance between providing greater insight and value while providing compliance with data protection regulations.10 Also, all source data for training should adhere to the three data-focused tenets: provenance (the history of the data throughout its lifecycle); context (the circumstances around data use); and integrity (data security and maintenance).11 During exploratory data analysis, the team of data scientists should consider not only the volume of available data, but also how diverse the sample is, whether all groups of customers are equally represented, and whether the human agents in any training scenarios made decisions that were fair to all customers. Focusing on these issues can allow the data scientists to apply appropriate data treatment strategies to reduce any embedded bias in the data, while also providing enhanced coverage (the model’s ability to make decisions) and accuracy (the model’s ability to make correct decisions).
  • 13. 13 NEURAL NETWORKS Brakes help a car go faster.12 2. Change your culture Bias can creep into a neural network not only through the training data, but also at the fine-tuning stage. For example, the model developer might discover that manually increasing the weighting attributed to certain factors can lead to more accurate results —but this might have an unintended negative impact on fairness. So it is important to change the culture of the data science teams by providing them with ethical and anti- discriminatory training, thereby increasing their awareness of protective characteristics, bias and ethicality. Leaders should also look to create diverse teams of data scientists and promote collaboration and peer reviews. 3. Keep experimenting When building a model, the data scientists should compare several algorithms and keep experimenting with them to evaluate their relative levels of suitability for the task at hand. In doing this, they should bear in mind that a neural network may not be the best choice for use cases where training data is scarce and where more transparent algorithms could play the same role. 4. Test and validate In addition to standard machine learning testing on 20% of the “holdout sample” or validation set, it is also advisable to conduct cross-validation, since this can reveal a model’s ability to generalize—which means making decisions on previously unseen cases. To allow this, the data sample used should be carefully selected to represent both frequently occurring scenarios and also boundary or “outlier” conditions. In applications such as fraud detection, where the amount of “live” fraudulent data is usually much smaller than non-fraudulent transactions, anomalous transactions should be deliberately selected or created for testing purposes. Finally, fairness testing should be carried out to complement the technical tests, and make sure that the model does not discriminate against or favor certain groups of customers. 5. Keep on top of documentation Each step of the model design process should be recorded, and the documentation about each model maintained and updated continuously throughout its entire lifecycle. The documentation should also be strictly governed while being made accessible to all relevant and authorized stakeholders. 6. Create a center of excellence for responsible AI To attain and sustain leadership in the use of neural networks, each financial services firm should set up a dedicated function to act as a center of excellence in the responsible use of AI, including neural networks. This central resource would establish preferred practices and standards, drive AI-focused thought leadership and research, and impose risk controls and governance so all use of AI across the organization is ethical and compliant. Dr. Rumman Chowdhury, Accenture Labs
  • 14. 14 NEURAL NETWORKS WHATNEXT? Effectively implementing a neural network is not the end of the story. As any AI model operates, learns and makes decisions, the world around it continues to change, and its performance may degrade over time. All of this means that controls and quality assurance should not stop after deployment but should be maintained and reviewed throughout the model’s entire lifecycle. Ongoing considerations include the following. Regulatory changes: Continuous monitoring of the regulatory environment is critical, both with respect to automated processes (such as changes in trade or AML laws) and AI legal requirements (such as explainability obligations or data handling restrictions). Accuracy and bias monitoring: Ongoing monitoring of accuracy and bias has to be maintained, to allow the neural network’s performance not to drop below defined thresholds and that its decisions do not systematically favor certain groups. Security and re-training data screening: Maintaining strict cyber security provisioning is vitally important. Also, as firms re-train their models to keep pace with changes in the wider environment, they should take account of the risk that “poisoning” training data with adversarial examples can skew neural networks’ reasoning, resulting in the models taking decisions that are incorrect and potentially illegal. And malicious access to the model itself—whether from inside or outside the firm —can compromise competitive advantage, and even lead to criminal misuse of the model, such as playing on stock market predictions. Quality assurance and audit: Many financial firms have already established a framework for traditional model validation, and in many cases have been using this for years. However, while this framework might be adequate for relatively simple models, firms should consider introducing adjustments and refinements to accommodate the higher complexity and ambiguity of neural networks and deep learning models. Plan B: There should always be a back-up model that the system can turn to automatically, in the event that the front-line model displays signs of degradation.
  • 15. 15 NEURAL NETWORKS CONCLUSION:APOWERFUL TOOL—TOBEUSEDWITHCARE There’s no doubt that neural networks are a powerful tool for financial services firms as they seek to improve efficiency, enhance the accuracy of their decision-making, boost revenues and improve the experience for customers. But like any other powerful tool, neural networks should be used with due care and consideration—and in the light of the fullest possible information. Authors Additional contacts Sabyasachi (Saby) Roy Managing Director Financial Services Technology Advisory Artificial Intelligence Lead UKI sabyasachi.a.roy@accenture.com Elena Khmeleva, PhD Technology Consultant Financial Services Technology Advisory Intelligent Automation UKI elena.khmeleva@accenture.com Elodie B. de Fontenay Director Financial Services Technology Advisory Offering Development Global elodie.b.de.fontenay@accenture.com David C. Jones Managing Director Financial Services Technology Advisory Intelligent Automation Global david.c.jones@accenture.com Tim Broome Managing Director Financial Services Technology Advisory Intelligent Automation APAC tim.broome@accenture.com
  • 16. About Accenture Accenture is a leading global professional services company, providing a broad range of services and solutions in strategy, consulting, digital, technology and operations. Combining unmatched experience and specialized skills across more than 40 industries and all business functions—underpinned by the world’s largest delivery network—Accenture works at the intersection of business and technology to help clients improve their performance and create sustainable value for their stakeholders. With more than 482,000 people serving clients in more than 120 countries, Accenture drives innovation to improve the way the world works and lives. Its home page is www.accenture.com References 1 “Global financial services industry bullish towards disruptive technology but widescale adoption yet to come,” Intertrust, November 28, 2018. 2 “#Augmented Finance & Machine Intelligence,” Autonomous Next, April 2018. 3 “How AI Boosts Industry Profits and Innovation,” Accenture, 2017. 4 “HSBC rolls out facial recognition for mobile,” Financial Times, May 8, 2018. 5 “DARPA Plans To Spend $2 Billion Developing New AI Technologies,” Forbes, September 7, 2018. 6 “Understanding Machines: Explainable AI,” Accenture 2018. 7 “Machine learning algorithm cheat sheet for Azure Machine Learning Studio,” Microsoft, March 3, 2019. 8 “Responsible AI Practices,” Google, 2019. 9 “Our approach: Microsoft AI principles,” Microsoft, 2019. 10 “What’s Your Data Strategy?,” Harvard Business Review, June 2017. 11 “Redefine Your Company Based on the Company You Keep,” Accenture, 2018. 12 Accenture Labs, March 11, 2019. Disclaimer: This document is intended for general informational purposes only and does not take into account the reader’s specific circumstances, and may not reflect the most current developments. Accenture disclaims, to the fullest extent permitted by applicable law, any and all liability for the accuracy and completeness of the information in this document and for any acts or omissions made based on such information. Accenture does not provide legal, regulatory, audit, or tax advice. Readers are responsible for obtaining such advice from their own legal counsel or other licensed professionals. Copyright © 2019 Accenture. All rights reserved. Accenture and its logo are trademarks of Accenture. 191109 Stay Connected Accenture Financial Services Technology Advisory www.accenture.com/us-en/services/financial- services/technology-advisory-index Connect With Us www.linkedin.com/showcase/16197660 Follow Us twitter.com/TechAdvisoryFS