Advisory Services

Rigorous AI compliance counsel for regulated financial institutions

We help banks, asset managers, and financial services firms build the governance infrastructure to deploy AI responsibly — and to demonstrate that responsibility to regulators.

What we do

Three practice areas. One integrated approach.

AI compliance in financial services is not a single problem. It spans model risk management, regulatory alignment, and the operational controls that sit between them. Our practice is organized around these three dimensions — and we work across all three, because the gaps between them are where institutions get into trouble.

01

AI Model Governance

Build the governance infrastructure regulators expect

SR 11-7 / OCC 2011-12 · NIST AI RMF · EU AI Act (Article 9)

SR 11-7 established the foundational framework for model risk management, but it was written before large language models, generative AI, and third-party AI APIs existed. We help institutions extend their MRM programs to cover the full spectrum of AI systems in use today — from traditional statistical models to foundation models and vendor-supplied AI tools.

Key deliverables

  • AI model inventory design and implementation
  • Model risk tiering and materiality assessment
  • Validation framework development for generative AI
  • Model documentation standards and templates
  • Governance committee charter and escalation protocols
  • SR 11-7 gap assessment and remediation roadmap

02

Regulatory Compliance & Readiness

Map your AI posture to what regulators actually expect

EU AI Act · SEC AI Guidance · CFPB Circular 2022-03 · FRB / OCC / FDIC

The regulatory landscape for AI in financial services is evolving rapidly and unevenly. The EU AI Act imposes extraterritorial obligations on U.S. institutions with European operations. The SEC has issued guidance on AI use in investment advice. The CFPB has signaled scrutiny of algorithmic decision-making in consumer credit. We help institutions understand what applies to them and what they need to demonstrate.

Key deliverables

  • EU AI Act applicability assessment and compliance roadmap
  • SEC AI guidance alignment review
  • CFPB algorithmic fairness and adverse action analysis
  • Regulatory examination preparation and mock reviews
  • Compliance program design and policy drafting
  • Cross-jurisdictional AI regulatory mapping

03

Operational Risk Management

Identify and control the risks AI introduces to your operations

Basel III Operational Risk · FFIEC IT Examination Handbook · DORA (EU)

AI systems introduce operational risks that traditional risk frameworks were not designed to capture: model drift, data quality degradation, third-party dependency, and the opacity of probabilistic outputs. We help institutions identify these risks, design controls, and integrate AI risk into their existing operational risk management programs.

Key deliverables

  • AI operational risk assessment and heat mapping
  • Third-party AI vendor due diligence framework
  • Data governance and lineage controls for AI inputs
  • Incident response and model failure protocols
  • AI risk appetite statement development
  • Integration with existing ORM and RCSA programs

How we engage

Structured engagements. Clear deliverables.

4–6 weeks

Assessment

A structured review of your current AI governance posture against applicable regulatory frameworks. Produces a gap analysis, risk prioritization, and a remediation roadmap with sequenced recommendations.

3–6 months

Program build

End-to-end design and implementation of an AI governance or model risk management program. Includes policy development, process design, tooling recommendations, and staff enablement.

Retainer

Ongoing advisory

Continuous access to our advisors for regulatory developments, examination preparation, and governance questions as they arise. Structured as a monthly retainer with defined response commitments.

As needed

Examination support

Targeted support for regulatory examinations, including pre-examination readiness reviews, document preparation, and examiner response support.

Who we serve

Built for regulated financial institutions

Regional & community banks

SR 11-7 compliance, model inventory, examination readiness

Asset managers

SEC AI guidance, investment model governance, third-party AI risk

Insurance carriers

Actuarial model governance, algorithmic underwriting controls

Broker-dealers

FINRA AI guidance, suitability model risk, surveillance AI

FinTech lenders

CFPB algorithmic fairness, adverse action explainability, UDAP risk

Credit unions

NCUA model risk guidance, proportionate governance frameworks

Ready to discuss your AI compliance posture?

We offer a complimentary 30-minute scoping conversation for prospective clients. No obligation — just a direct conversation about where your institution stands and what it needs.

Get started

  • Complimentary 30-minute scoping call
  • No retainer required for initial engagement
  • Proposal delivered within five business days
  • Senior advisor involvement from day one
Schedule a conversation