Industries
AI Your Regulators and Your Customers Can Trust
GLBA and the Safeguards Rule, FFIEC guidance, NYDFS 23 NYCRR 500, SOX IT general controls, SEC cyber-disclosure obligations, PCI DSS, SOC 2, extended to cover the models now making and supporting decisions inside your business.
The reality
Overlapping Supervisors, and Examiners Who Ask for Evidence
Few industries carry this much overlapping obligation: a prudential expectation here, a state cybersecurity rule there, a disclosure requirement for public filers, a card-brand standard, and a customer assurance framework on top. The obligations rarely conflict, but they each want their own evidence, and an examiner’s request is not the moment to start assembling it.
One advantage worth naming: model risk governance was a discipline in this industry before anyone called it AI governance. The vocabulary is already yours, inventory, validation, monitoring, challenge. What’s new is the range of models and how quickly they arrived.
The tension
Consequential Decisions, at Machine Speed, with a Paper Trail Expected
Where a model touches credit, pricing, eligibility, fraud, or servicing, the questions are familiar and sharper: what does it use, how was it validated, who reviews the outcome, how do you detect disparate impact, and can a customer get an explanation. Generative systems complicate it further, a summarizer that shapes an adviser’s recommendation is in the decision path even though nobody classified it as a model.
How we help
Extend the Governance You Already Have
AI Inventory and Risk Tiering
Including the generative tools that didn’t come through model risk, and the AI features inside vendor platforms.
Framework Extension
ISO/IEC 42001 and NIST AI RMF mapped onto your existing GLBA, FFIEC, NYDFS, and SOX control environment rather than beside it.
Model Governance Support
Validation expectations, monitoring, challenge, and documentation for a broader class of models than your framework was written for.
Third-Party AI Oversight
Diligence and contract terms for vendors whose AI now processes your customers’ data.
Security and Assurance
vCISO leadership, testing, SOC 2 and PCI DSS programs, and examiner-ready evidence.
Proof
Regulated, Examined, Documented
a decade advising cyber insurance carriers and underwriters, useful on both sides of a financial institution’s own insurance renewal.
FISMA System Security Plan
A federally required SSP with stringent standards. We identified risks, designed the controls, and produced a compliant plan the client could stand behind.
Multi-Business-Unit HIPAA Risk Assessment
Data flow mapping, boundary definition, and a gap assessment across a shared-services structure.