CFB testimony - Ryan on implementation costs and timeline

For that reason, we are relatively confident in our ability to implement this new mandate, though significant resources and time will be required.

We have formed an agency-wide AI working group, and we are learning more every day.

Shifting the strategy to a disclosure model means the council would be placing an entirely new administrative and enforcement mandate onto the campaign finance board.

Nevertheless, AI technology is evolving at such a rapid pace that we cannot say with certainty how best to regulate its use in elections.

We want to be realistic about the timeline and resources that would be required to implement this legislation.

To that end, we appreciate that the amended version of this legislation meaningfully addresses our most significant legal and implementation concerns shared at the hearing in December 2024.

We are still researching the exact technology and staffing costs associated with implementing the bill, but we anticipate that the cost would be steep and that it would take, at a minimum, a year to implement after bill passage.

By shifting from a prohibition to a disclosure model and naming the CFB as the agency in receipt of these disclosures, as well as naming the CFB as the agency responsible for implementing the new disclosure regime,

This estimate includes both updating our existing candidate and independent spending reporting systems and building an entirely new internal system to receive

the Council eliminated the greatest vulnerabilities to First Amendment legal challenge and clarified administrative and enforcement responsibilities.

and to make public the provenance data and other similar ad information we would be receiving from candidates and independent spenders.

The CFB has a unique perspective on this topic rooted in our dual mandate to serve candidates and voters.