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ABA: The American Bankers Association
Comment Letter

Letter to OSTP on the Request for Information regarding Regulatory Reform on Artificial Intelligence

  • From Ryan T. Miller
  • Published October 27, 2025

Re: Docket No. OSTP-TECH-2025-0067, ABA Comment Letter to the Office of Science and Technology Policy responding to its Request for Information regarding Regulatory Reform on Artificial Intelligence

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Dear Ms. Murphy,

The American Bankers Association (ABA) appreciates the opportunity to respond to the Request for Information regarding Regulatory Reform on Artificial Intelligence ("RFI"). We are providing the banking industry’s views on existing Federal statutes, regulations, agency rules, guidance, forms, and administrative processes that unnecessarily hinder the development, deployment, and adoption of artificial intelligence (AI) technologies within the United States.

ABA and our members enthusiastically support the principles underpinning the Trump Administration's AI Action Plan (Plan), released in July 2025. Banks are a unique sector already subject to an extensive compliance regime covering nearly all risks associated with AI, including fair lending and cybersecurity requirements. Federally regulated financial institutions undergo supervision, examination, and enforcement of their use of any technology, including AI. For example, banks are subject to model risk management guidance.

Accordingly, we make the following bank-specific recommendations that policymakers can pursue:

  • Updates to Supervisory Guidance on Model Risk Management. Supervisory guidance on model risk management predates technological advances and should undergo updates, subject to notice and comment, to account for current market practices and internal controls.
  • Bank Field Examination Reform. The prudential banking agencies must continue to revamp their examination procedures in order to foster a regulatory environment that supports responsible innovation.
  • Encouragement of Voluntary Standards and Certifications (AI Centers of Excellence). Policymakers should encourage the development of voluntary standards and certification programs within the AI supply chain to allow for appropriate due diligence. Developers and deployers should not have to choose among explainability, risk management, and commercial best practices. Over time, these voluntary programs will mature into federated AI Centers of Excellence providing value to banks of all sizes as well as the broader ecosystem.
  • Congressional action. Congress must assert its authority over AI policy in order to protect interstate commerce from a patchwork of state laws and ensure American leadership in this vital sector of the global landscape. At the same time, these federal laws must not create duplicative or inconsistent requirements for the highly regulated banking industry.

Download the comment letter to read the full text.

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Ryan T. Miller

Vice President & Senior Counsel, Innovation Policy

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