Letter Responding to the Request for Information on the Development of an AI Action Plan

Dear Ms. Plimpton,

The American Bankers Association (ABA) appreciates the opportunity to provide input from the financial services industry into the Development of an Artificial Intelligence (AI) Action Plan ("Plan"). This Plan, as directed by President Trump's Executive Order issued on January 23, 2025, will define the priority policy actions needed to sustain and enhance America's AI dominance, and to ensure that unnecessarily burdensome requirements do not hamper private sector AI innovation. We hope these comments are helpful in formulating the Plan and look forward to working with the policymakers tasked under it on more specific deliverables.

The world has been captivated by the reality and promise of generative AI since its public unveiling in late 2022. It has powered investment, fueled dreams, and inspired new ways of thinking. It has the potential to improve the daily lives of individual Americans even while impacting geopolitics on the grandest scale. Currently, the leading AI developers call the United States of America home. But if US leadership in the field of AI is to be preserved, it will be necessary for the federal government to foster an environment of trust and consistency. Without meaningful standards to channel efforts in a constructive manner, companies scrambling for dominance would be so many "crabs in a bucket" seeking an edge over competitors.

Such an arrangement simply will not work given the interconnectedness of the AI ecosystem, in which Big Tech companies develop large language models (LLMs), downstream companies deploy these LLMs for particular use cases, and end users (agents or customers of the deployer) utilize these applications. The reliance of companies on third party entities in this arrangement is clear, driving home the need for baseline standards and due diligence.

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