Re: NIST AI Executive Order
The American Bankers Association (ABA) appreciates the opportunity to comment on the request for information (RFI) related to National Institute of Standards and Technology's (NIST) assignments under sections 4.1, 4.5 and 11 of the October 30, 2023 Executive Order on Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence as published in the Federal Register on December 21, 2023 (EO).
NIST is uniquely positioned to build upon the success of its AI Risk Management Framework (AI RMF) by developing a complement to address the unique opportunities and challenges presented by generative AI (GenAI) and prompt-based large language models (LLMs). We urge NIST to continue to approach any new content for the AI RMF as industry-agnostic, customizable, and non-binding. At the same time, NIST should recognize the prominent role it enjoys in the ecosystem, which will only increase in the wake of the EO. The AI RMF and any supplemental materials may become an integral part of each sector’s best practices, integrated into contractual provisions, and referenced by regulatory agencies. Accordingly, NIST must thread the needle to find the appropriate balance between universality and fitting into existing regulatory regimes.
In summary, the ABA:
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