June 9, 2021

Chief Counsel’s Office
Attention: Comment Processing
Office of the Comptroller of the Currency
400 7th Street SW
Suite 3E–218
Washington, DC 20219

Ann E. Misback
Secretary
Board of Governors of the Federal Reserve System
20th Street and Constitution Avenue NW
Washington, DC 20551

James P. Sheesley
Assistant Executive Secretary
Attention: Comments-RIN 3064–ZA24
Federal Deposit Insurance Corporation
550 17th Street NW
Washington, DC 20429

Comment Intake
Bureau of Consumer Financial Protection
1700 G Street NW
Washington, DC 20552

Melane Conyers-Ausbrooks
Secretary of the Board
National Credit Union Administration
1775 Duke Street
Alexandria, VA 22314–3428

Re: Request for Information and Comment on Financial Institutions’ Use of Artificial Intelligence, Including Machine Learning

To the Above-Listed Agencies:

The Securities Industry and Financial Markets Association (“SIFMA”)1 welcomes the opportunity to present its views to the Board of Governors of the Federal Reserve System, the Bureau of Consumer Financial Protection, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of the Comptroller of the Currency (collectively, the “Agencies”) in response to the Agencies’ request for information and comment on financial institutions’ use of artificial intelligence (“AI”), including machine learning (the “Request”).2

SIFMA’s response on behalf of its members focuses on general principles and approaches that might usefully guide regulators’ consideration of issues that arise in this context. In the sections that follow, the response describes financial institutions’ extensive risk identification and mitigation processes that have long focused on technology-related risks specific to the financial services industry. Those risks take many forms, now specifically including AI-related risks. The response also discusses how those processes enable financial service providers to respond to many of the particular concerns and issues raised in the questions posed in the Request, and how those existing and evolving risk management processes enable financial service providers to continue to address emergent AI-related risks. At the same time, financial service providers continue to secure the extensive benefits that AI capabilities provide to consumers and the industry.

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 Information and Comment on Financial Institutions’ Use of Artificial Intelligence, Including Machine Learning, 86 Fed. Reg. 16837 (March 31, 2021), https://www.govinfo.gov/content/pkg/FR-2021-03-31/pdf/2021-06607.pdf.