The American Bankers Association (ABA) is a trade association representing banks operating in the United States. Its AI advocacy rests on the position that banks are already supervised for AI-related risk under existing prudential, consumer-protection and model-risk frameworks, and that new AI regulation should therefore be federal, risk-based, and preemptive of state law rather than layered on top of bank supervision (Source: bankingjournal.aba.com).
Policy positions
Federal preemption of state AI law
In an August 14, 2026 submission responding to a request for information issued by Democrats on the House Financial Services Committee, the ABA told the committee that Congress should establish a nationally harmonized, risk-based framework for regulating AI in financial services that would preempt state laws while assuring consumer-protection and cybersecurity outcomes. The association urged Congress to assert leadership over AI policy to avoid a patchwork of state laws, and stated that any such laws "should create baseline standards that are not duplicative or inconsistent with the enterprise risk management obligations of banks." The submission was prepared in consultation with the association's AI Working Group and answered questions ranging from AI adoption to the use of third-party providers (Source: bankingjournal.aba.com). Reporting on the same submission described it as running to 21 pages and as anchoring the request for a federal framework in "existing prudential, consumer, cybersecurity, privacy, model-risk, third-party-risk, and operational-resilience frameworks" (Source: insideaipolicy.com; article body not retrieved beyond the lede).
The association has taken the same preemption position in other venues, including a joint letter to the Treasury Department on its request for information on uses of AI, which urged that any new horizontal federal AI law preempt state requirements and exclude banks from duplicative obligations, and a letter to the Office of Science and Technology Policy on regulatory reform arguing that Congress must assert authority over AI policy to protect interstate commerce from a state-law patchwork (Sources: aba.com; aba.com).
Technology neutrality and regulatory perimeter
The ABA argues that existing federal statutes address AI risk in a technology-neutral manner, citing the Gramm-Leach-Bliley Act, and frames the substantive problem as one of regulatory perimeter rather than of AI as such: "The real challenge has to do with a level playing field. Although banks and other depository institutions are supervised for compliance, other types of entities are not, even though they also deliver financial products and services." Ensuring the act's obligations "are observed by all entities, regardless of what financial services they provide, would go a long way to protecting consumers and preventing data leakage and breaches," the association stated (Source: bankingjournal.aba.com). The same submission stressed that Congress must act to supplement administration efforts on cybersecurity.
Regulatory engagement
The association files comment letters across the federal and international AI-governance apparatus. Dated filings include a July 22, 2026 letter to the Financial Stability Board on its consultation report on sound practices for responsible adoption of AI; a March 9, 2026 joint letter to NIST on its request for information regarding security considerations for AI agent systems; and a February 12, 2026 joint trades letter on the NIST AI Risk Management Framework. It published staff FAQs on the interagency revisions to model risk management guidance on May 12, 2026 (Source: aba.com).
The association identifies the revised interagency model risk management expectations issued by the Federal Reserve, the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation as the most important supervisory guidance bearing on bank AI use. It notes that the guidance as revised in April 2026 carves out generative and agentic AI while applying to traditional AI, and that the guidance nonetheless states a bank's risk management and governance practices should guide the determination of appropriate governance and controls even for applications the guidance does not cover (Source: aba.com). The relevant issuances are Federal Reserve SR letter 26-2 (April 17, 2026), OCC Bulletin 2026-13, and FDIC FIL-15-2026.
Member-facing activity
Alongside advocacy, the association publishes guidance and training for member banks. It maintains an AI Policy Template, updated June 25, 2026 with a section on AI agents, offered as a drafting guide rather than a compliance product; a March 26, 2026 report, Artificial Intelligence in Banking; and March 2, 2026 recommendations for policymakers on mitigating AI-powered attacks against identity and authentication. It convenes an AI Working Group covering use cases, practices, risks and security threats, and which supplies feedback on agency requests. Its staff experts on the subject are Brooke Ybarra, Senior Vice President for Innovation and Strategy; Ryan Jackson, Vice President for Innovation Strategy; and Ryan T. Miller, Vice President and Senior Counsel for Innovation Policy (Source: aba.com).
The association testified before the Senate Special Committee on Aging on protecting seniors from AI-generated fraud on July 29, 2026 (Source: aba.com).
The association characterizes bank AI use as having a decades-long history in traditional applications — fraud detection and prevention, marketing, cybersecurity, anti-money-laundering activity, credit underwriting and customer service — with generative AI applications still nascent and member attention focused on risk management, governance and controls (Source: aba.com).
Relationships
- related: Financial Services — AI Deployment — the sector whose AI deployment and supervision the association's positions address.
- related: AI Federalism, State-Level AI Regulation — the preemption question its submissions turn on.
- related: NIST AI Risk Management Framework 1.0, National Institute of Standards and Technology (NIST) — subject of a February 2026 joint trades letter and a March 2026 joint letter on AI agent security.
- related: Financial Stability Board (FSB) — the body whose July 2026 consultation on responsible AI adoption it responded to.
- regulated-by: the Federal Reserve, the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation — the prudential regulators whose model risk management guidance the association treats as the governing supervisory expectation for bank AI.
Open questions
- Whether the House Financial Services Committee Democrats' request for information produces legislative text, and whether any resulting bill adopts the preemption the association requested, is not yet public.
- The full 21-page submission text was not retrieved; the characterizations above rest on the association's own summary in its banking journal and on a trade-press lede.