Banking and financial services

The decision was automated. The accountability was not.

Credit, trading, payments, onboarding and surveillance decisions are moving to models and agents. The obligation to evidence them did not move anywhere.

On this page

The problem Decisions moved to models and agents; the obligation to evidence them did not move anywhere.
Who the record has to satisfy A prudential examiner, a model validator, an external auditor, a customer or a court, and a supervisor abroad.
Where it bites first Authority, independence and conformance, in that order.

The problem

Few industries have a decision-governance tradition as mature as banking's. Delegated lending authority, model risk management, four-eyes approval, trade surveillance, adverse action notice, management assertion — every one of them exists to answer the same question. Who decided this, under what authority, and can you show me?

Automation has outrun the evidence. A model or an agent now participates in credit decisions, payment authorization, customer onboarding, exception handling and surveillance triage. The institution retains every obligation it had before, and holds, in place of a decision record, an application log written by the application that acted. The revised model risk guidance excludes generative and agentic AI from its scope; a request for information on those systems is promised.

The exposure is concentrated where the examination is hardest. A fair-lending review, a model validation, a regulatory examination, a customer complaint, a litigation hold — each asks the institution to evidence a specific past decision to a party that has no reason to take the institution's word for it, and each is answered today with records the institution produced about itself.

Independent challenge is already expected in this industry. The only question is whether the evidence it examines is independent too.

Who the record has to satisfy

The examiner was not in the room.

An examiner does not take the institution’s word for a decision. The examiner tests the record the institution did not get to edit.

A prudential examiner testing whether decisions stayed inside delegated authority
A model validation function expected to challenge with sufficient independence
An external auditor supporting a management assertion
A customer, a plaintiff, or a court, in an adverse action or a dispute
A supervisor abroad, applying an operational resilience regime to the same firm

Where it bites first

Three of the six, in this order.

AUTHORITY

Evidencing that an automated credit, payment or trading decision was inside the delegated authority in force at the time.

INDEPENDENCE

Producing a decision record that an examiner or a validator can check without relying on the acting system.

CONFORMANCE

Turning examination readiness from a project into a property of the running system.

All six →

The demonstration

Built around your problem, not around our example.

An agent proposes, the decision is adjudicated against authority, and anyone you authorize can verify it afterward. Tell us which of the six is costing you, and that is the one we will build.

Start a conversation Read the argument

We are not asking you to trust us. We are asking you to let us prove it.

The decision was automated. The accountability was not.

The examiner was not in the room.

Three of the six, in this order.

A Combatant Commander cannot prove an autonomous action stayed within authority. No fielded system can.

The control action fired. The authority for it is a matter of reconstruction.

On whose authority was that clinical decision taken?

You sign the attestation. What actually stands behind the signature?

Built around your problem, not around our example.