AI in financial services
Financial-services AI tends to sit in credit, fraud, the customer conversation, and the recommendation a person treats as advice. The Intelligence Audit reads those uses from the inside, including the duties that change with the charter and the product.
How AI shows up
A model prices credit or ranks an application. A fraud or financial-crime tool flags a transaction. A service bot answers before a banker does. Research summaries and next-best-action tools shape what a representative says. Marketing models choose who is offered a product.
Many of those models are a vendor's, switched on inside a platform the firm already bought. Others are built inside one line of business and never added to the model inventory. Both are uses. The audit does not stop at the inventory the model-risk group maintains.
Rules the audit looks at
The names below are examples the Regulatory and Compliance part and the Sector Controls part look at with your counsel. Listing one is not a determination that it applies to you, and it is not legal advice.
- The Equal Credit Opportunity Act (ECOA), where a system touches credit
- Banking model-risk guidance such as SR 11-7, where the firm is supervised as a bank
- SEC and FINRA duties, where a system shapes a recommendation, a communication, or supervision at a broker-dealer or an investment adviser
- The Gramm-Leach-Bliley Act (GLBA), for customer information at a financial institution
- The Colorado AI Act, where a system makes or strongly shapes a consequential decision about a person, including credit
A community bank, a broker-dealer, and a nonbank lender do not carry the same charter. The audit does not pretend that they do. Your counsel confirms which duties apply to the product in front of you. We do not issue a fair-lending opinion or a supervisory rating.
What the audit checks
Sector Controls tests the industry controls against real records. In financial services that includes model validation and fair lending where credit is in scope: who owns the model, what data it uses, what the adverse-action record says, and whether a challenge can stop the use. Regulatory and Compliance maps the jurisdictions and the charter with your counsel.
Go-to-Market covers lead scoring, offer models, outreach, and the claims made about a product or a rate. The TCPA and the FTC are examples of the rules involved, not a legal opinion. Vendor and contract review matters because a platform feature can decide more than the contract describes. Decision rights and the security review still apply.
Before we walk you through it, every Intelligence Audit is reviewed with our counsel. The review is ours, and it is not legal advice to you. The next step after the Assessment report is the Discovery Call.
Questions about this sector
Is model-risk guidance only for banks?
Banking model-risk guidance such as SR 11-7 is written for supervised banking organizations. A nonbank lender or a broker-dealer can face a different set of duties and still use models the same way. The audit asks what the model decides and which regime applies. It does not treat every financial firm as a bank.
How does the audit treat fair lending?
Where a system touches credit, Sector Controls looks at the data, the owner, the reason a person can be given, and whether the use can be stopped. ECOA is an example, looked at with your counsel. The audit does not issue a fair-lending determination, and it is not legal advice.
Do SEC and FINRA rules belong in an AI audit?
They belong where a system shapes a recommendation, a communication to a customer, or how the firm supervises that activity. They do not belong to every back-office tool. The audit separates them. Your counsel confirms the registration and the rule. We do not act as the firm's chief compliance officer.
How an engagement with us works
- 01
Intelligence Assessment
A short written read from your answers and what is public
Read - 02
Discovery Call
We talk through the organization and the decision in front of you
Read - 03
Scope and Agreement
Scope is agreed in writing before the audit begins
Read - 04
Intelligence Audit
Eleven parts of work from the inside, and the architecture sits inside that work
Read - 05
Roadmap Preparation
The implementation plan for 90 days, 6 months, and 12 months
Read - 06
Counsel Review
Our counsel reviews the audit before we walk you through it. It is not legal advice to you.
Read - 07
Audit Delivery
The report, the architecture map, the plan, and a leadership readout
Read - 08
Ongoing Advisory
We stay when a capability or a rule changes
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