The requisite level and type of explainability will depend, in part, on the role of the individual using the model. The bank employees that interact with machine learning models will naturally have varying roles and varying levels of technical knowledge.
The dividend restrictions guarded against capital depletion in the event that some banks experienced unexpectedly large losses, while still allowing firms that could support them to pay out dividends. Late last month, the Board extended the distribution limitations onto the fourth quarter amid the continued uncertainty.