With New Action Plan, White House Launches AI "Space Race"—What Banks Should Know
The White House has issued an AI Action Plan that aims to position the United States as the leader in artificial intelligence ("AI"), as part of a broader pattern of boosting innovation and reducing regulatory burden, with inevitable consequences for financial services.
On July 23, 2025, the White House unveiled "Winning the AI Race: America's AI Action Plan" (the "Plan"), a sweeping blueprint designed to cement U.S. leadership in AI across the public and private sectors. The Plan follows the administration's objective to promote the rapid development, domestic deployment, and global diffusion of U.S.-origin AI technologies in public and private sector applications, while minimizing regulatory friction.
The Plan is structured around three pillars: accelerate AI innovation, build American AI infrastructure, and lead in international diplomacy and security. It pledges to: (i) rescind or revise regulations deemed to "unnecessarily hinder" AI; (ii) condition certain federal funding on a state's regulatory stance toward AI; and (iii) revise procurement rules to contract only with AI developers that commit to maintaining free-speech safeguards and eliminating "top-down ideological bias."
The Plan sets forth a large-scale blueprint for action on AI, calling for actionable regulation and nimble federal oversight. This could point toward the analytical framework for the revision of existing guidance from the Office of the Comptroller of the Currency ("OCC"), Federal Deposit Insurance Corporation ("FDIC"), Federal Reserve, or Consumer Financial Protection Bureau on model governance and adverse action notices that have been viewed as creating a barrier to wider adoption of AI in financial institutions, particularly in client-facing and credit-decisioning applications.
Newly confirmed Comptroller of the Currency Jonathan Gould pledged to "embrac[e] innovation within the agency and the banking system." Gould's OCC is likely to adopt and concur with the approach set forth in a recent speech by Rodney E. Hood, as the prior acting Comptroller. Acting FDIC Chair Travis Hill has said that "[t]he FDIC should also consider issuing additional guidance on several topics, such as fintech partnerships, artificial intelligence, and digital assets and tokenization." Under new leadership in 2025, the banking agencies are poised to support, not restrict, AI innovation by banks, in a manner consistent with bank safety and soundness. Given the recent release of the Plan, banking organizations should engage with the banking agencies in the near term, with a focus on revisions to guidance on model governance and adverse action notices to remove regulatory barriers to the use of AI.
