BPI Responds to Office of Science and Technology Policy’s National Priorities for Artificial Intelligence

Executive Summary

The Bank Policy Institute (“BPI”) [1], through its technology policy division known as BITS[2], appreciates the opportunity to respond to OSTP’s National Priorities for Artificial Intelligence request for information.

The financial services industry recognizes the transformative potential of AI and its capacity to enhance our industry’s services, promote economic growth and expand access to financial products and services, improve customer experiences, and bolster the security and integrity of financial transactions.

For decades, the financial services industry has been at the forefront of responsible technological innovation while maintaining the highest standards of trust, safety, security, and customer service. As we evaluate the increasing capabilities of AI and the potential benefits it may provide consumers and the economy more broadly, we bring with us this wealth of experience and a deep understanding of the importance of innovating responsibly.

We are committed to the responsible use and development of AI technologies, underpinned by strong governance, oversight, and risk management. The banking industry’s foundational adherence to, and experience with, robust risk management practices, including model risk management, IT risk management, cyber risk management, enterprise risk management, operational risk management and resilience, data security, and privacy, can be effectively leveraged to assist in establishing a framework designed to allow for the responsible use of AI within the financial services sector. A programmatic and coordinated risk-based approach, leveraging existing architectures, should be the cornerstone of the national AI strategy.

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[1] The Bank Policy Institute is a nonpartisan public policy, research, and advocacy group, representing the nation’s leading banks and their customers. Our members include universal banks, regional banks and the major foreign banks doing business in the United56 States. Collectively, they employ almost 2 million Americans, make nearly half of the nation’s small business loans and are an engine for financial innovation and economic growth.

[2] BITS – Business, Innovation, Technology, and Security – is BPI’s technology policy division that provides an executive level forum to discuss and promote current and emerging technology, foster innovation, reduce fraud, and improve cybersecurity and risk management practices for the nation’s financial sector.