Shea Brown suggests modifying Intro 2602 validator role

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And you actually heard the deputy commissioner say that, that they can't find somebody inside of New York City to say that.

We're going to hear from Shea Brown.

And you actually heard the deputy commissioner say that, that they can't find somebody inside of New York City to say that.

Shay, if you're on and ready, please unmute yourself.

And you actually heard the deputy commissioner say that, that they can't find somebody inside of New York City to say that.

Jay?

And you actually heard the deputy commissioner say that, that they can't find somebody inside of New York City to say that.

Can you hear me now?

Yes, we can hear you.

And you actually heard the deputy commissioner say that, that they can't find somebody inside of New York City to say that.

Thank you, Speaker Menon and members of the committee for this opportunity to speak.

And you actually heard the deputy commissioner say that, that they can't find somebody inside of New York City to say that.

My name is Shea Brown.

I'm the CEO of Babble AI, a company that audits high-risk AI systems for safety and effective governance.

And you actually heard the deputy commissioner say that, that they can't find somebody inside of New York City to say that.

And we've been independent bias auditors under Local Law 144 since that law first took effect.

And you actually heard the deputy commissioner say that, that they can't find somebody inside of New York City to say that.

I'd like to speak today in support of Proposal 2602.

And you actually heard the deputy commissioner say that, that they can't find somebody inside of New York City to say that.

An AI system that affects the public should be examined by a qualified party outside the company that built it before it reaches the public.

And you actually heard the deputy commissioner say that, that they can't find somebody inside of New York City to say that.

And you actually heard the deputy commissioner say that, that they can't find somebody inside of New York City to say that.

I further think that New York City is the right place for this to start, and we'd like to see it done in a way that is effective and promotes the public's well-being.

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I'd like to raise two points, and I offer more in my written testimony.

And you actually heard the deputy commissioner say that, that they can't find somebody inside of New York City to say that.

First, the bill asks the outside validator to certify that a model is appropriately positioned for deployment.

And you actually heard the deputy commissioner say that, that they can't find somebody inside of New York City to say that.

From our experience, we believe this is more than an outside party can reasonably say, given the third-party dynamics and access to the system in question.

And you actually heard the deputy commissioner say that, that they can't find somebody inside of New York City to say that.

And you actually heard the deputy commissioner say that, that they can't find somebody inside of New York City to say that.

Instead, we suggest potentially requiring the developer to make written assertions about its compliance over specific topics and to a minimum standard that is set by the city.

And you actually heard the deputy commissioner say that, that they can't find somebody inside of New York City to say that.

And you actually heard the deputy commissioner say that, that they can't find somebody inside of New York City to say that.

And an independent practitioner validates those assertions through careful testimony.

And you actually heard the deputy commissioner say that, that they can't find somebody inside of New York City to say that.

testing, verification, and inspection.

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This puts the burden of proof back on the developer and does not force the auditor to make a judgment call that it's not in the best position to make.

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My second point involves the validator's independence and competence.

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The only requirement for a validator in the current draft is that it not be an affiliate of the developer.

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We ask that qualification be more closely tied to existing standards and or accreditation for independent assurance and certification bodies that exist today.

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And you actually heard the deputy commissioner say that, that they can't find somebody inside of New York City to say that.

While the subject matter is unique and requires careful thought, the frameworks for professional conduct of third-party audit assurance and validation professionals already exist and we should leverage that.

And you actually heard the deputy commissioner say that, that they can't find somebody inside of New York City to say that.

And you actually heard the deputy commissioner say that, that they can't find somebody inside of New York City to say that.

Thank you for your time, and I'm happy to answer any questions.

And you actually heard the deputy commissioner say that, that they can't find somebody inside of New York City to say that.

Thank you so much.