AI Compliance Checklist - Financial Services Edition

Overview

Financial services AI faces more regulatory requirements than any other industry. Banking regulators expect SR 11-7 model risk management for AI. Fair lending examiners scrutinize AI credit decisions for discrimination. SEC and FINRA require AI disclosures and suitability for investment recommendations. Consumer protection regulators watch for unfair or deceptive AI practices.

This comprehensive checklist provides financial institutions with actionable compliance requirements across all major regulatory frameworks. It's designed for examination readiness—helping you not just comply, but demonstrate compliance when regulators ask.

What's Inside

• Financial AI Regulatory Map: Which regulations apply to which AI use cases (credit, trading, fraud, collections, customer service)
• SR 11-7 Model Risk Management Checklist: Development requirements, validation requirements, ongoing monitoring, and governance—with AI-specific extensions
• Fair Lending Compliance Checklist: ECOA/Regulation B requirements, FCRA compliance, disparate impact testing, and adverse action notice requirements for AI credit decisions
• SEC & FINRA Compliance Checklist: Suitability requirements for AI recommendations, algorithmic trading compliance, disclosure requirements, and supervision obligations
• Consumer Protection Checklist: UDAP/UDAAP requirements for AI, FTC Act compliance, and state consumer protection laws
• Privacy & Data Protection Checklist: GLBA requirements, CCPA for financial data, and emerging state privacy laws
• AML/BSA Compliance Checklist: Requirements for AI in transaction monitoring, suspicious activity reporting, and customer due diligence
• Vendor Management Checklist: Third-party AI risk management per OCC 2013-29 and SR 13-19/23-4
• Examination Preparation Guide: What examiners ask, documentation to prepare, and common findings to avoid
• 90-Day Compliance Roadmap: Prioritized approach to achieving compliance across frameworks

Who This Is For

• Chief Risk Officers responsible for AI in risk frameworks
• Model Risk Management teams overseeing AI validation
• Compliance Officers managing regulatory requirements
• Fair Lending Officers ensuring non-discrimination
• Technology Leaders deploying compliant AI systems

Why This Resource

Financial regulators have detailed expectations for AI—and they examine for compliance. This checklist is designed for examination readiness: it covers not just what requirements exist, but what documentation examiners expect and how to avoid common findings.

The examination preparation guide provides specific guidance on regulatory interactions, MRA/MRIA responses, and remediation planning.

FAQ

Q: How does SR 11-7 apply to AI models?

A: SR 11-7 applies to all models including AI. The checklist extends SR 11-7 requirements with AI-specific considerations: explainability, bias testing, data drift monitoring, and third-party model assessment. It helps you satisfy SR 11-7 while addressing AI's unique characteristics.

Q: What about fair lending for AI credit decisions?

A: Fair lending receives extensive coverage: prohibited basis testing, proxy discrimination analysis, disparate impact assessment, and—critically—generating specific adverse action reasons from AI models (per CFPB Circular 2022-03).

Q: How do we prepare for examinations?

A: The examination preparation guide covers what different regulators (OCC, Fed, FDIC, CFPB, SEC, FINRA) typically ask about AI, what documentation to have ready, and common examination findings to avoid.