The Software & Information Industry Association (SIIA) provided comments on two NIST draft documents: NIST AI 600-1, focusing on the AI Risk Management Framework for Generative AI, and NIST AI 100-5, concerning global AI standards engagement. SIIA, representing nearly 400 companies in various digital content and technology sectors, made several recommendations for AI 600-1. These include clarifying the scope of generative AI (GAI), incorporating a risk-based assessment of GAI systems, distinguishing responsibilities among different AI actors, and tailoring foundational actions to specific risk profiles and the capacities of small- and medium-sized enterprises. SIIA emphasized balancing transparency with security and intellectual property concerns, and the need for flexibility in auditing practices due to the lack of standardization. For AI 100-5, SIIA supports NIST’s global engagement plan and recommends enhancing domestic capacity-building efforts, including grants for small- and medium-sized enterprises to participate in international standards meetings.
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