Industry Battlecard
Banking
OCC, FDIC, and CFPB have all issued AI risk guidance. Third-party LLM use without governance is a Matter Requiring Attention waiting to happen.
Shadow AI risk
Branch and ops staff use ChatGPT to summarize loan files, customer complaints, and AML alerts.
Common use cases
- · Loan file summarization
- · Complaint response drafting
- · AML narrative writing
- · Vendor due diligence
Compliance impact
GLBA
OCC 2023-17
NYDFS Part 500
BSA/AML
Conversation starter
"Your peers are getting MRAs over AI usage in middle office. Have your examiners started asking about AI inventories yet?"
Discovery questions
- ·How are you handling SR 11-7 model risk management for LLMs?
- ·Do you have visibility into which AI tools your call center is using?
- ·What's the plan for the OCC AI examination expected next cycle?
Recommended collateral
- Banking Battlecard
- SR 11-7 + LLM Whitepaper
