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The Divergence Conundrum - How AI’s Redefining of Financial Risk Widens Governance Gaps
Financial institutions are rapidly rethinking AI governance as machine learning and Generative AI push beyond traditional model risk frameworks. Model Risk expert Chris Smigielski outlines how Arvest Bank broadens oversight to include non-traditional AI tools, builds an AI Center of Excellence, and emphasizes risk-based governance, transparency, and human oversight.
Dec 31, 2025
Chris Smigielski
Chris Smigielski, Model Risk Director, Arvest Bank
Tags: Model risk
The Divergence Conundrum - How AI’s Redefining of Financial Risk Widens Governance Gaps
The views and opinions expressed in this content are those of the thought leader as an individual and are not attributed to CeFPro or any other organization
  • AI risk management must go beyond rigid definitions to capture all relevant risks

  • Arvest Bank adapts SR 11 7 to oversee AI and non traditional tools like fraud monitoring and AML systems

  • AI Center of Excellence manages inventory assessment and monitoring for AI tools outside model risk scope

  • Performance monitoring for GenAI is complex and needs automated scalable solutions

  • Governance prioritizes use case specific risk levels and human oversight needs

  • Vendor transparency on fairness and bias is essential and lack of proof is flagged

  • Regulation is fragmented but proactive principle based governance is pursued

  • AI literacy with mandatory employee training ensures safe and effective adoption

  • Governance must balance innovation with oversight and accountability

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