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· AI has become a top emerging risk on every bank boardroom agenda
· Predictive AI offers immediate benefits in
balance sheet optimization and customer behavior modeling
· Generative AI use remains narrow due to
governance gaps and risks like hallucinations
Existing SR 11-7 model risk frameworks cover
Predictive AI but need adapting for Generative AI
· Impact-based tiering and sandbox testing are
key guardrails for responsible Generative AI adoption
· Automation is reshaping workflows, shifting
value from data collection to strategic interpretation
· Banks must avoid “model definition arbitrage”
to prevent hidden risks while encouraging innovation
· Trust-ready adoption requires balancing
Predictive AI’s maturity with cautious Generative AI exploration