NTIA Request for Comments on AI Accountability 

April 19, 2023

The National Telecommunications and Information Administration (NTIA), an agency within the federal Department of Commerce which advises the President on telecommunications and information policy issues, recently issued a request for comments (RFC) regarding artificial intelligence (AI) accountability. The NTIA’s RFC seeks input from AI stakeholders on regulatory and self-regulatory policies that would support the development of AI audits, assessments, certifications, and other methods of providing reliable evidence about the safety, trustworthiness, and effectiveness of AI systems. Overall, the NTIA’s goal is to develop a strong AI assurance and accountability ecosystem. NTIA’s RFC comes after the National Institute of Standards and Technology published it’s voluntary AI Risk Management Framework on January 26, 2023.

Mirroring the broader trend in the world of business and technology, Cozen O'Connor has seen a recent marked surge in clients who include AI in the technology products they make available to their customers, as well as with regard to clients’ use of AI systems that are included as a component of licensed IT systems and software. The rapid proliferation of AI, and especially the recent surge in the use of large language models (LLMs) such as ChatGPT-4, have sparked debate about what it means for AI systems to be responsibly trained, managed, and deployed. Establishing a common robust framework for AI trustworthiness and accountability will ultimately benefit both vendors and customers alike.

There is reason to believe that some type of AI regulatory regime will be put in place in the U.S. For example, Majority Leader Schumer recently announced he is going to prioritize AI legislation. Clients should expect activity in both the regulatory and legislative space over the next two years on AI. Responding to the RFC presents an opportunity for clients to provide information to regulators about their experiences in AI and their concerns about benefits and drawbacks of potential regulations.

The deadline for responding to the NTIA’s RFC is June 10, 2023.

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Christopher Dodson



(215) 665-2174

Benjamin Mishkin



(215) 665-2171

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Please contact Christopher DodsonBen Mishkin, and Varun Krovi at Cozen O'Connor with any questions.