Bank Ready AI · Governed Build Specification
AI-Driven Embedded Finance & Third-Party Oversight
BaaS & Fintech Partnership RiskCommunity Bank or Credit Union · BaaS / fintech programsStatus: Configured
This specification is written to be circulated: to risk, to compliance, to technology, and to the examiner. Part I documents the technical build. Part II documents the human capability that makes it defensible.
Part I
The Technical Build
Model & Retrieval
- Vendor AI review platform (hosted LLM — ARMAI-style intelligent review engines)
- RAG grounded in policies, SOC reports, contracts, and regulatory guidance
- Structured + unstructured ingestion across the vendor evidence file
Deployment
- Risk/compliance staff portal with API into vendor-management systems
- Agentic due-diligence and compliance-lifecycle workflow automation
- Deployed alongside the core processor's infrastructure (Jack Henry at FFBKC)
Controls
- Human-in-the-loop review of every AI risk determination — no automated vendor actions
- Examiner-ready audit trail: every assessment traceable to source evidence
- Explainability on risk scores and flagged findings
- PII / NPI handling under GLBA safeguards
- Recursive governance: the oversight tool is itself a third-party AI vendor with its own TPRM file, model-inventory entry, and validation cadence
Channels
- Risk & compliance staff portal
- API / back-end integration with vendor-management systems
Part II
The Human Build
AI Compliance Officer
Keeps the oversight program — and the tool itself — inside the regulatory perimeter.
Visible skills
BSA/AML Compliance · Regulatory Exam Preparation · AI Audit & Internal Controls
Governance depth
Emerging AI Regulation Tracking · AI Policy Development · Model Risk Management (SR 26-2 / NCUA)
IT Lead for AI Integration
Connects the review platform to vendor-management and core systems.
Visible skills
Core Banking Platform Integration · API Integration & Development · AI Vendor API Management
Governance depth
AI Security & Data Privacy · On-Premises / Hybrid AI Deployment · AI Model Inventory & Lifecycle Tracking
AI Governance Committee Member
Owns the recursive-governance question: who governs the tool that governs your vendors?
Visible skills
Board & Executive Reporting · Third-Party AI Risk Management · AI Ethics & Responsible AI
Governance depth
AI Governance Committee Leadership · AI Risk Framework Alignment (NIST AI RMF) · AI Training & Awareness
Part III
The Integration Plan
Confirmed adopters of this use case: First Federal Bank of Kansas City.
Phase 1 · Foundation — Govern the tool before it governs anyone
Technical workstream
- Vendor due diligence on the oversight platform itself — the recursive step comes first
- Ringfence input sources: which policies, contracts, and SOC reports the engine may ingest
Human workstream
- Stand up the TPRM file and model-inventory entry for the AI tool itself
- Committee approves scope, risk appetite, and the five evidence outcomes as the acceptance bar
Phase 2 · Pilot — One partner, parallel-run against manual review
Technical workstream
- Run AI due diligence on a single fintech partner alongside the existing manual process
- Benchmark AI evidence outputs against the manual file for completeness and accuracy
Human workstream
- Risk staff disposition AI findings with documented rationale
- Committee reviews parity results and the audit-trail quality before expansion
Phase 3 · Production — Full portfolio on the evidence-outcome cadence
Technical workstream
- Expand to the full partner portfolio with monitoring dashboards
- Automate evidence-outcome documentation for examination requests
Human workstream
- Quarterly board reporting on program risk posture
- Annual revalidation of the oversight tool — recursive governance as a standing agenda item
Part III
Verification Benchmarks
- Five evidence outcomes produced per partner review: risk analysis, use-case documentation, vendor governance, failure response, performance monitoring
- Parallel-run parity: AI due-diligence file matches or exceeds manual review completeness
- Audit-trail traceability: every risk determination resolves to named source evidence
- Recursive-governance check: the tool's own TPRM file and validation stay current
- Adopter assets
- ~$1B
- Customers served
- 25,000
- Evidence outcomes
- 5
- Adopters / vendors
- 1 / 1
First Federal Bank of Kansas City, Q1 2026
Across 9 Kansas City-metro branches
Risk, use case, vendor, failure, monitoring — the examiner checklist
FFBKC × ARMAI — early-mover recursive-governance pattern