Letter to NIST on the Artificial Intelligence Risk Management Framework

Dear Ms. Chambers,

The American Bankers Association (ABA) appreciates the opportunity to respond to the request for comments (RFC) on the draft documents responsive to the National Institute of Standards and Technology’s (NIST) assignments under Executive Order 14110 (Sections 4.1, 4.5 and 11). In particular, ABA is offering feedback to the initial public draft of NIST AI 600-1, the Generative Artificial Intelligence Profile (AI 600-1).

ABA previously filed a comment letter responding to NIST's Request for Information publishedon December 21, 2023. In that letter, ABA cited the high reputation of the industry-agnostic,voluntary, and customizable NIST AI Risk Management Framework (AI RMF) and made anumber of suggestions for NIST to consider as it accounted for new issues presented bygenerative artificial intelligence (GAI). ABA also previously provided informal feedback as apublic volunteer to the NIST GAI-PWG. We are grateful that NIST factored theserecommendations into its initial public draft of AI 600-1.

ABA appreciates AI 600-1's positioning as a "companion resource" to the AI RMF, intended to function as a supplement rather than a parallel system. As an example of the AI RMF’s implementation for a particular use-case, the profile will likely be consulted more frequently than its parent due to its practical nature. ABA members have shared that AI 600-1 is very comprehensive and adequately captures risks created or exacerbated by GAI. However, the information contained in much of the document is laid out in an extremely dense manner, particularly the bulk of Section 3. The other sections, especially Section 2 and Appendix A, are far more readable.

Download the comment letter to read the full text.