Letter to the Financial Stability Board on its Sound Practices for Responsible Adoption of Artificial Intelligence Consultation Report

To Whom It May Concern:

The American Bankers Association (ABA) appreciates the opportunity to respond to the Financial Stability Board's (FSB) Sound Practices for Responsible Adoption of Artificial Intelligence Consultation Report (Consultation Report). Overall, our members found the report directionally sound and potentially of significant benefit to their institutions. However, we do have some targeted suggestions that we believe would make the deliverable even more effective, and we hope the FSB considers them in this spirit.

The following comments are based on discussions with ABA’s AI Working Group, which is an interdisciplinary body of data scientists, technologists, compliance, legal, risk, security, audit, and human resources experts representing banks of all sizes. This group routinely comes together to formulate policy positions as well as to discuss operational best practices. Our comments are also informed by the work of the Financial Services Sector Coordinating Council's R&D Committee.

Our members are particularly appreciative that the Consultation Report takes a proportionate, outcomes focused approach. ABA encourages the U.S. banking agencies to consider the FSB’s sound practices as a helpful input into their ongoing AI-related guidance, supervisory, and policymaking efforts.

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