June 12, 2023

Stephanie Weiner
Acting Chief Counsel
National Telecommunications and Information Administration
U.S. Department of Commerce
1401 Constitution Avenue NW, Room 4725
Washington, D.C. 20230

Re: Response to Request for Comments on AI Accountability Measures and Policies

Dear Ms. Weiner:

The Securities Industry and Financial Markets Association (“SIFMA”)1 welcomes the opportunity to respond to the National Telecommunications and Information Administration (“NTIA”) request for public comment on AI system accountability measures and policies (the “Request”).2 SIFMA recognizes that maintaining public trust in AI applications is essential to realizing the enormous benefits that AI has to offer, and that recent developments in AI across economic sectors support the establishment of certain controls.

SIFMA, on behalf of its members, encourages policymakers to consider the following key issues in any future regulatory policies involving AI:

• Policymakers should adopt a governance framework for AI that is risk-based and not overly prescriptive. An AI governance framework should treat AI models, algorithms, applications, and systems (collectively, “AI applications”) differently depending on the likelihood or severity of the potential harm they might cause. Such a framework would subject low-risk AI applications to different compliance obligations than high-risk applications.

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).

2 Request for Comment on Artificial Intelligence System Accountability Measures and Policies, 88 Fed. Reg. 22433 (April 7, 2023), https://www.govinfo.gov/content/pkg/FR-2023-04-13/pdf/2023-07776.pdf.