By: Jean-Phillippe Beaudet

On August 14, The Digital Chamber submitted a response to House Financial Services Committee Democrats’ Request for Information on artificial intelligence in financial services and housing. The AI + Quantum Working Group answered more than 30 of the Committee’s questions on explainability, liability, third-party risk, capital markets, housing, data centers, and international development. 

Read our full response HERE. 

TDC’s response makes three arguments: 

First, existing law already covers most of what worries people about AI in finance. The Equal Credit Opportunity Act, the Fair Housing Act, the Fair Credit Reporting Act, and Dodd-Frank’s UDAAP provisions don’t carve out an exception for a decision a model made instead of a person. Congress’s first job is reviving and enforcing the rules already on the books, rather than building a parallel AI-specific regime. 

Second, compliance claims should be provable, rather than asserted by private companies. Tamper-evident action logs, cryptographic attestations, and verifiable model and data provenance records let a regulator or a court confirm which system acted, on what data, and whether the record was altered afterward. None of that replaces governance, testing, or supervision, but it strengthens self-certification with an authoritative audit trail. 

Third, liability should follow function and control, rather than a party’s position in the supply chain. A developer that sets a model’s behavior, and that a deployer can neither inspect nor alter, should answer to the consumer. We also asked Congress for the reverse protection: a safe harbor for content-neutral infrastructure. Compute, storage, and validation networks that carry AI without selecting or training the models running on them shouldn’t be treated as developers or deployers simply for existing, and that protection should apply whether the infrastructure is centralized or distributed. 

Data Centers, Front and Center 

We also weighed in on AI data centers. We asked the Federal Energy Regulatory Commission to assign the transmission and generation costs a large load causes to that load, instead of spreading them across every customer in the region. We asked Congress to give the Energy Information Administration authority to collect mandatory facility-level reporting on power and water use, because fragmentary data reporting obligations leave communities without the information they need to make informed decisions. And we pointed the Committee to decentralized AI architectures, workloads distributed across many smaller machines instead of concentrated in one location, as a way to ease grid pressure and democratize the AI stack. 

Committee Democrats will fold this response into future hearings and legislation on AI in financial services and housing. TDC’s position gives them a path that doesn’t force a choice between protecting consumers and letting the industry keep building: rules that already exist, evidence a regulator can check, and liability that lands on whoever actually controls the outcome. 

Read TDC’s full library of comment letters and reports at www.digitalchamber.org. Questions can be sent to policy@digitalchamber.org.