The letter, submitted on behalf of SIIA and various associations, raises concerns about the proposed Customer Identification Program (CIP) and its limited effectiveness in addressing national security threats posed by malicious cyber activities. Instead, the associations recommend focusing on the Abuse of IaaS Products Deterrence Program (ADP) and industry collaboration to develop cybersecurity best practices. They highlight potential privacy implications of the CIP, especially internationally, which could erode trust in U.S. IaaS providers and hinder global business relationships. Additionally, the letter suggests splitting the rule to separately consider AI model reporting requirements to allow for more thorough consideration of legal, technical, and policy concerns, while also proposing scoping these requirements to countries of concern to avoid diplomatic strains with allies. Despite these concerns, the associations express commitment to working with the U.S. government to achieve shared national security objectives.