The Real Constraint
Most firms don't have an AI problem. They have an AI accountability problem.
Everyone's experimenting. Vendors are adding AI to everything. Regulators are watching. Leadership knows AI matters — but nobody's answered the harder question: Who signs off when it's wrong?
The Questions that Remain Unanswered:
Who owns AI risk when a model makes a lending decision?
What does "explainable" actually mean to an examiner?
Where does AI governance sit — compliance, tech, or both?
How do we adopt AI without creating regulatory exposure?
What does defensible documentation look like?
Business risk first, technology second AI strategy has to answer to the same governance standards as every other material risk in the business — not sit outside them.
Compliance is a design partner, not a gate The firms that move fastest are the ones that build governance in from day one, not bolt it on after an exam finding.
Evidence beats confidence A model that "seems right" isn't defensible. A model with a documented, examined trail is.