The IIF has submitted comments in response to the U.S. Treasury’s (UST’s) request for information (RFI) on “Uses, Opportunities, and Risks of Artificial Intelligence in the Financial Services Sector,” published on June 6, 2024. The IIF considers this RFI very timely in view of both the growth in potential applications for AI in the financial sector and the increasing official sector focus globally. We applaud the UST’s fact-finding efforts on this important topic.

Our comments draw upon member feedback from the 2023 IIF-EY Public Survey Report on AI/ML use in financial services, discussions with our AI/ML Experts Group comprised of senior business representatives across our global membership, and frequent bilateral contacts with our members. Among other items, we highlight existing sectoral and cross-sectoral regulation of AI in finance as well as financial institutions’ existing risk management governance frameworks, systems and controls. At this stage, the IIF does not believe that technology-specific regulation in the U.S. with respect to AI as a broad category, or within just the financial services industry, is warranted or desirable; we encourage the official sector to focus on supervisory measures, including fact-finding and research, in the short- to medium-term.