March 13, 2025

Submitted via federalregister.gov
AI Action Plan
Attn: Faisal D’Souza
NCO
National Science Foundation
2415 Eisenhower Ave.
Alexandria, VA 22314, USA

Re: Request for Information on the Development of an Artificial Intelligence (AI) Action Plan

Dear Mr. D’Souza:

The Securities Industry and Financial Markets Association and its Asset Management Group (collectively, “SIFMA”)¹ welcome the opportunity to respond to the request for information on the Office of Science and Technology Policy (OSTP) AI Action Plan.² SIFMA believes AI has and will continue to offer many benefits to US investors, financial markets, and financial institutions, but the impacts of unnecessary laws and regulation on AI will have an irreversible negative impact on the competitiveness of US financial markets.

Any new law and regulation should be designed to address and minimize tangible risks that are not otherwise covered by existing requirements. To date, there have been no identified risks associated with the use of AI by financial institutions that are not otherwise covered by existing laws and regulations. Until such risks present themselves, any new law or rule should be carefully considered so as to avoid unnecessarily stifling the development of AI technology.

As such, SIFMA is deeply concerned that the proliferation of state legislation and regulations purporting to govern the development and use of AI will severely inhibit SIFMA members’ (1) continued use of AI applications that have been in use for decades (including non-generative AI applications), and (2) ability to develop and/or deploy new AI technology or new use cases for AI. As we have clearly seen for privacy laws, conflicting state laws can create obstacles to responsible technology development in the United States. Accordingly, SIFMA supports federal legislation that would preempt state AI laws.

SIFMA’s white paper, Promoting Investor Success, Industry Innovation, and Efficiency with AI, offers useful insights into the challenges of regulating any specific technology particularly AI and other emerging technologies. A copy of this white paper is attached and can also be found on our website.³

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SIFMA would be pleased to discuss the views expressed here or in the attached white paper if that would assist your deliberations on this issue. Please feel free to contact us at [email protected] or [email protected] if you would like to discuss these issues further.

Sincerely,

Melissa MacGregor
Deputy General Counsel & Corporate Secretary
SIFMA

Kevin Ehrlich
Managing Director & Associate General Counsel
SIFMA AMG

Attachment: SIFMA White Paper: Promoting Investor Success, Industry Innovation, and Efficiency with AI

1. SIFMA is the leading trade association for broker-dealers, investment banks, and asset managers operating in the U.S. and global capital markets. On behalf of our members, we advocate for legislation, regulation, and business policy affecting retail and institutional investors, equity and fixed income markets, and related products and services. We serve as an industry coordinating body to promote fair and orderly markets, informed regulatory compliance, and efficient market operations and resiliency. We also provide a forum for industry policy and professional development. SIFMA, with offices in New York and Washington, D.C., is the U.S. regional member of the Global Financial Markets Association (GFMA).

   SIFMA’s Asset Management Group (“SIFMA AMG”) brings the asset management community together to provide views on U.S. and global policy and to create industry best practices. SIFMA AMG’s members represent U.S. and global asset management firms that manage more than 50% of global assets under management. The clients of SIFMA AMG member firms include, among others, tens of millions of individual investors, registered investment companies, endowments, public and private pension funds, UCITS and private funds such as hedge funds and private equity funds. For more information, visit http://www.sifma.org/amg. [↩]

2. Request for Information on the Development of an Artificial Intelligence (AI) Action Plan https://www.federalregister.gov/documents/2025/02/06/2025-02305/request-for-information-on-the-development-of-an-artificial-intelligence-ai-action-plan. [↩]
3. SIFMA White Paper available at https://www.sifma.org/wp-content/uploads/2024/09/AI-Whitepaper-Promoting-Investor-Success-Industry-Innovation-and-Efficiency-with-AI.pdf [↩]