AI / Chatbot Virtual Agent — impact tolerance ≤ same day (subject to precondition below) — ITOL

Impact tolerance: ≤ same day (subject to precondition below) — any outage without adequate human fallback that delays invocation of a statutorily clocked right (e.g., Reg E error-resolution intake) (illustrative default — trace the derivation, then replace with your own harm analysis)

Definition: AI-driven conversational interface handling customer inquiries, account servicing requests, and in some deployments dispute intake or basic transaction execution.

Why it is designated: The CFPB's 2023 chatbot issue spotlight warns that poorly performing conversational AI can prevent consumers from getting information needed to invoke rights such as Reg E error-resolution. This effectively couples chatbot availability and quality to those regulatory clocks, even though the chatbot itself has no independent SLA (service-level agreement).