Letter to the HFSC on the Request for Information on AI Risks and Modernization in Financial Services

Dear Ranking Member Waters,

The American Bankers Association (ABA) appreciates the opportunity to respond to the House Financial Services Committee Democrats' Request for Information on AI Risks and Modernization in Financial Services (RFI).

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 (FSSCC) R&D Committee.

Please see ABA's responses to the questions below. Please note that we elected not to respond to every question; instead, we focused on areas in which we could deliver the most value.

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