SIIA Response to BIS Proposed Rule on the Development of Advanced AI Models and Computing Clusters

SIIA has submitted comments on the Bureau of Industry and Security’s (BIS) proposed rule regarding reporting requirements for the development of advanced AI models and computing clusters. While SIIA supports the intent of the rule, aligned with Executive Order 14110’s goal of ensuring safe, secure, and trustworthy AI development, the organization raises concerns about the operational burden of the proposed quarterly reporting schedule. SIIA suggests a less frequent reporting cadence, such as semi-annual or annual, to better balance national security needs with innovation and industry capabilities.

Additionally, SIIA recommends BIS streamline its data collection process to focus on critical national security concerns and enhance the confidentiality and security of sensitive data. The letter also urges BIS to consider international harmonization of reporting requirements to avoid undue burdens on companies operating in multiple jurisdictions.

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