{"slug":"governance","title":"How banks control AI","intro":"Banks that explain how AI is overseen, for example through a committee, a policy, model risk management or human review.","keywords":["governance","control","controls","oversight","committee","policy","model risk","responsible ai"],"year":2025,"numbers":{"n":87,"total":270,"pct":0.3222},"trend":[{"year":2022,"n":8,"total":298,"pct":0.0268},{"year":2023,"n":15,"total":297,"pct":0.0505},{"year":2024,"n":41,"total":284,"pct":0.1444},{"year":2025,"n":87,"total":270,"pct":0.3222}],"banks":[{"slug":"bank-of-hawaii-corp","name":"Bank of Hawaii Corp","state":"HI","size_group":"$1B to $50B","max_detail":3,"quote":{"passage_id":"0000046195-26-000015-77dc964b3727","quote":"in 2025 we rolled out three training modules for employees to complete in order to gain access to our artificial intelligence (“AI”) tool Microsoft Co-Pilot.","link":"https://www.sec.gov/Archives/edgar/data/46195/000004619526000015/boh-20251231.htm#:~:text=islands%20and%20the%20West%20Pacific%20assisting%20our%20employees,artificial%20intelligence%20%28%E2%80%9CAI%E2%80%9D%29%20tool%20Microsoft%20Co%2DPilot.","mention_words":"Using AI now","detail_words":"Concrete example"}},{"slug":"capital-bancorp-inc","name":"Capital Bancorp Inc","state":"MD","size_group":"$1B to $50B","max_detail":3,"quote":{"passage_id":"0001419536-26-000073-ec972d076ce3","quote":"Capital Bank uses data analytics, including AI and proprietary models, throughout the OpenSky™ customer lifecycle to support fraud prevention and credit decisioning.","link":"https://www.sec.gov/Archives/edgar/data/1419536/000141953626000073/cbnk-20251231.htm#:~:text=Capital%20Bank%20uses%20data%20analytics%2C%20including%20AI%20and,over%20the%20life%20of%20the%20relationship.","mention_words":"Using AI now","detail_words":"Concrete example"}},{"slug":"fifth-third-bancorp","name":"Fifth Third Bancorp","state":"OH","size_group":"$50B and above","max_detail":3,"quote":{"passage_id":"0000035527-26-000124-e21300cce0a1","quote":"Fifth Third launched a comprehensive platform designed to deliver leadership development content and experiences for leaders at all levels. Several new development offerings were launched, including generative Artificial Intelligence (“AI”) training","link":"https://www.sec.gov/Archives/edgar/data/35527/000003552726000124/fitb-20251231.htm#:~:text=In%202025%2C%20Fifth%20Third%20launched%20a%20comprehensive%20platform,the%20organization.%20Fifth%20Third%20leaders%20participated","mention_words":"Using AI now","detail_words":"Concrete example"}},{"slug":"first-financial-corp-in","name":"First Financial Corp","state":"IN","size_group":"$1B to $50B","max_detail":3,"quote":{"passage_id":"0000714562-26-000014-f997aa999336","quote":"The Corporation implemented a form of AI with its intelligent digital assistant, Gabby, available through the Bank’s website.","link":"https://www.sec.gov/Archives/edgar/data/714562/000071456226000014/thff-20251231x10k.htm#:~:text=The%20Corporation%20implemented%20a%20form%20of%20AI%20with,financial%20condition%2C%20and%20results%20of%20operations.","mention_words":"Sees AI as a risk","detail_words":"Concrete example"}},{"slug":"princeton-bancorp-inc","name":"Princeton Bancorp, Inc.","state":"PA","size_group":"$1B to $50B","max_detail":3,"quote":{"passage_id":"0001193125-26-106151-7c4bb0cd2667","quote":"These include Sophos for advanced cybersecurity threat detection and response, Verafin for fraud detection and AML compliance, the Glia Chatbot for enhancing customer service interactions, and CATO Networks for AI-driven network security and optimization.","link":"https://www.sec.gov/Archives/edgar/data/1913971/000119312526106151/bprn-20251231.htm#:~:text=The%20Bank%20does%20not%20utilize%20AI%20for%20decision%2Dmaking,the%20Company%E2%80%99s%20business%20or%20financial%20results.","mention_words":"Using AI now","detail_words":"Concrete example"}},{"slug":"us-bancorp-de","name":"U.S. Bancorp","state":"MN","size_group":"$50B and above","max_detail":3,"quote":{"passage_id":"0000036104-26-000011-a564cd6b7195","quote":"The Company also launched an “AI Essentials Channel” on Skills Academy, which is designed to help team members build skills in effectively using Company-approved artificial intelligence tools in their daily work.","link":"https://www.sec.gov/Archives/edgar/data/36104/000003610426000011/usb-20251231.htm#:~:text=As%20part%20of%20its%20talent%20strategy%2C%20the%20Company,development%20and%20customer%20and%20business%20needs.","mention_words":"Using AI now","detail_words":"Concrete example"}},{"slug":"ally-financial-inc","name":"Ally Financial Inc.","state":"MI","size_group":"$50B and above","max_detail":2,"quote":{"passage_id":"0000040729-26-000005-654900cf70b7","quote":"advancing technology that powers dealer and consumer centric products and services leveraging our ongoing investment in data and AI","link":"https://www.sec.gov/Archives/edgar/data/40729/000004072926000005/ally-20251231.htm#:~:text=Our%20long%2Dterm%20strategic%20objectives%20are%20centered%20around%20%281%29,implementation%20of%20AI%20and%20automation%20solutions.","mention_words":"General statement about AI","detail_words":"Names an area"}},{"slug":"amalgamated-financial-corp","name":"Amalgamated Financial Corp.","state":"NY","size_group":"$1B to $50B","max_detail":2,"quote":{"passage_id":"0001823608-26-000048-6c142ef787cc","quote":"The NYDFS's requirement that banks maintain a comprehensive data lineage for AI models to prove they are not inadvertently using proxies for protected classes","link":"https://www.sec.gov/Archives/edgar/data/1823608/000182360826000048/amal-20251231.htm#:~:text=%E2%80%A2The%20NYDFS%27s%20requirement%20that%20banks%20maintain%20a%20comprehensive,codes%20as%20a%20proxy%20for%20race.","mention_words":"Sees AI as a risk","detail_words":"Names an area"}},{"slug":"american-express-co","name":"American Express Co","state":"NY","size_group":"$50B and above","max_detail":2,"quote":{"passage_id":"0000004962-26-000080-08c74c1bb1dd","quote":"We have established, and continue to maintain, policies and a governance framework to comply with applicable laws and requirements in these areas, meet evolving customer and industry expectations and support and enable business innovation and growth","link":"https://www.sec.gov/Archives/edgar/data/4962/000000496226000080/axp-20251231.htm#:~:text=Regulatory%20and%20legislative%20activity%20in%20the%20areas%20of,our%20business%20and%20heightened%20regulatory%20scrutiny.","mention_words":"Explains how AI is controlled","detail_words":"Names an area"}},{"slug":"ameris-bancorp","name":"Ameris Bancorp","state":"GA","size_group":"$1B to $50B","max_detail":2,"quote":{"passage_id":"0000351569-26-000050-08d6bdfc6d22","quote":"Our adoption of artificial intelligence, including generative artificial intelligence, machine learning and similar tools and technologies that collect, aggregate, analyze or generate data or other materials or content (collectively, “AI”), for limited internal use has increased our efficiency","link":"https://www.sec.gov/Archives/edgar/data/351569/000035156926000050/abcb-20251231.htm#:~:text=Our%20adoption%20of%20artificial%20intelligence%2C%20including%20generative%20artificial,to%20which%20we%20are%20a%20party.","mention_words":"Sees AI as a risk","detail_words":"Names an area"}},{"slug":"avidbank-holdings-inc","name":"Avidbank Holdings, Inc.","state":"CA","size_group":"$1B to $50B","max_detail":2,"quote":{"passage_id":"0001437749-26-008852-232dffadcf79","quote":"we currently use a software product with AI technology to enhance our fraud detection capabilities for our clients’ banking activity","link":"https://www.sec.gov/Archives/edgar/data/1443575/000143774926008852/avbh20251231_10k.htm#:~:text=We%20intend%20to%20selectively%20incorporate%20AI%20technology%20in,their%20business%20processes%2C%20services%20or%20products.","mention_words":"Using AI now","detail_words":"Names an area"}},{"slug":"bank-of-america-corp-de","name":"Bank of America Corp","state":"NC","size_group":"$50B and above","max_detail":2,"quote":{"passage_id":"0000070858-26-000157-1d80ced0abb1","quote":"Under our Enterprise Model Risk Policy, Model Risk Management is required to perform end-to-end model oversight, including independent validation before initial use, implementation monitoring, ongoing monitoring reviews through outcomes analysis and benchmarking, and periodic revalidation.","link":"https://www.sec.gov/Archives/edgar/data/70858/000007085826000157/bac-20251231.htm#:~:text=We%20use%20models%20enterprise%2Dwide%2C%20including%20to%20forecast%20losses%2C,from%20applications%20that%20rely%20on%20AI.","mention_words":"Explains how AI is controlled","detail_words":"Names an area"}},{"slug":"bank-of-new-york-mellon-corp","name":"Bank of New York Mellon Corp","state":"NY","size_group":"$50B and above","max_detail":2,"quote":{"passage_id":"0001390777-26-000033-b52237004074","quote":"We also consider data-related risks in the execution of our business objectives and processes, including the development of new products and services, including artificial intelligence applications.","link":"https://www.sec.gov/Archives/edgar/data/1390777/000139077726000033/bk-20251231_d2.htm#:~:text=We%20also%20consider%20data%2Drelated%20risks%20in%20the%20execution,our%20clients%20across%20the%20investment%20lifecycle.","mention_words":"Explains how AI is controlled","detail_words":"Names an area"}},{"slug":"bankwell-financial-group-inc","name":"Bankwell Financial Group, Inc.","state":"CT","size_group":"$1B to $50B","max_detail":2,"quote":{"passage_id":"0001505732-26-000046-4f6331353f4f","quote":"our current and potential future use of AI to support loan origination processes may introduce additional risk of inaccurate, incomplete, or misrepresented information","link":"https://www.sec.gov/Archives/edgar/data/1505732/000150573226000046/bwfg-20251231.htm#:~:text=When%20originating%20loans%2C%20we%20rely%20extensively%20on%20information,that%20all%20misrepresentations%20will%20be%20detected.","mention_words":"Sees AI as a risk","detail_words":"Names an area"}},{"slug":"baycom-corp","name":"BayCom Corp","state":"CA","size_group":"$1B to $50B","max_detail":2,"quote":{"passage_id":"0001730984-26-000016-68a20b7e64b4","quote":"Mitigating these risks requires a robust governance framework, regularly testing and auditing of AI models, and strong human oversight.","link":"https://www.sec.gov/Archives/edgar/data/1730984/000173098426000016/bcml-20251231x10k.htm#:~:text=Mitigating%20these%20risks%20requires%20a%20robust%20governance%20framework%2C,are%20critical%20to%20managing%20these%20risks.","mention_words":"Explains how AI is controlled","detail_words":"General"}},{"slug":"bok-financial-corp","name":"Bok Financial Corp","state":"OK","size_group":"$50B and above","max_detail":2,"quote":{"passage_id":"0000875357-26-000013-66de03b124b9","quote":"Each initiative is subject to a specific internal governance process designed to assess risks related to data quality, bias, regulatory compliance, and ethical considerations.","link":"https://www.sec.gov/Archives/edgar/data/875357/000087535726000013/bokf-20251231.htm#:~:text=We%20continue%20to%20evaluate%20and%20selectively%20deploy%20emerging,or%20services%20they%20provide%20to%20us.","mention_words":"Sees AI as a risk","detail_words":"Names an area"}},{"slug":"byline-bancorp-inc","name":"Byline Bancorp, Inc.","state":"IL","size_group":"$1B to $50B","max_detail":2,"quote":{"passage_id":"0001193125-26-083194-8dde194f67eb","quote":"address material risks from potential cybersecurity threats, including threats utilizing generative AI, and to facilitate the governance and oversight of cybersecurity risks","link":"https://www.sec.gov/Archives/edgar/data/1702750/000119312526083194/by-20251231.htm#:~:text=We%20have%20developed%20an%20Information%20Security%20Program%20%28the,and%20actual%20cyber%20threats%20and%20incidents.","mention_words":"Explains how AI is controlled","detail_words":"Names an area"}},{"slug":"cvb-financial-corp","name":"CVB Financial Corp","state":"CA","size_group":"$1B to $50B","max_detail":2,"quote":{"passage_id":"0001193125-26-083221-30ae17d337b9","quote":"We have adopted an AI Policy that establishes a governance framework for developing, deploying, and managing AI and Generative AI (GenAI) solutions and initiatives, including those involving vendors.","link":"https://www.sec.gov/Archives/edgar/data/354647/000119312526083221/cvbf-20251231.htm#:~:text=We%2C%20or%20our%20third%20party%20vendors%2C%20clients%20or,misappropriate%20funds%20and%20to%20facilitate%20cyberattacks.","mention_words":"Explains how AI is controlled","detail_words":"Names an area"}},{"slug":"capital-city-bank-group-inc","name":"Capital City Bank Group Inc","state":"FL","size_group":"$1B to $50B","max_detail":2,"quote":{"passage_id":"0000726601-26-000007-5f4d1d37e0a2","quote":"associated with assessing the proper operation of AI models, understanding","link":"https://www.sec.gov/Archives/edgar/data/726601/000072660126000007/ccbg-20251231.htm#:~:text=associated%20with%20assessing%20the%20proper%20operation%20of%20AI%20models%2C%20understanding","mention_words":"Explains how AI is controlled","detail_words":"Names an area"}},{"slug":"capital-one-financial-corp","name":"Capital One Financial Corp","state":"VA","size_group":"$50B and above","max_detail":2,"quote":{"passage_id":"0000927628-26-000024-0a3e3b63733d","quote":"Our risk reporting and risk management, including our business decisions that are based on information gathered through models and AI, depend on the effectiveness of our models and AI.","link":"https://www.sec.gov/Archives/edgar/data/927628/000092762826000024/cof-20251231.htm#:~:text=The%20development%20and%20implementation%20of%20some%20of%20these,the%20foregoing%20could%20have%20negative%20consequences.","mention_words":"Sees AI as a risk","detail_words":"Names an area"}},{"slug":"chain-bridge-bancorp-inc","name":"Chain Bridge Bancorp Inc","state":"VA","size_group":"$1B to $50B","max_detail":2,"quote":{"passage_id":"0001628280-26-020177-78a4a9a38a57","quote":"We have incorporated, and may in the future further incorporate, AI technology in certain business processes, services, and products, including technologies that process sensitive financial and/or personal data. We currently rely on AI tools and models provided by third-party vendors","link":"https://www.sec.gov/Archives/edgar/data/1392272/000162828026020177/chnbrdg-20251231.htm#:~:text=We%20have%20incorporated%2C%20and%20may%20in%20the%20future,that%20allow%20the%20creation%20of%20custom","mention_words":"Using AI now","detail_words":"Names an area"}},{"slug":"schwab-charles-corp","name":"Charles Schwab Corp","state":"TX","size_group":"$50B and above","max_detail":2,"quote":{"passage_id":"0000316709-26-000009-93fbbb4a565e","quote":"Schwab manages model risk, including use of artificial intelligence, through use of policies, standards, and controls which evaluate the conceptual and technical soundness of models used by the Company. Prior to the use of any artificial intelligence, we employ procedures which require","link":"https://www.sec.gov/Archives/edgar/data/316709/000031670926000009/schw-20251231.htm#:~:text=Model%20risk%20is%20the%20potential%20for%20adverse%20consequences,performance%20monitoring%20of%20the%20Company%E2%80%99s%20models.","mention_words":"Explains how AI is controlled","detail_words":"Names an area"}},{"slug":"citigroup-inc","name":"Citigroup Inc","state":"NY","size_group":"$50B and above","max_detail":2,"quote":{"passage_id":"0000831001-26-000011-e28bb076e0c8","quote":"overseeing and reviewing information from management regarding Citi’s approach to Generative AI and reviewing reports on technology and data quality-related matters.","link":"https://www.sec.gov/Archives/edgar/data/831001/000083100126000011/c-20251231.htm#:~:text=security%29%2C%20technology%20resource%20and%20talent%20planning%2C%20and%20technology,on%20technology%20and%20data%20quality%2Drelated%20matters.","mention_words":"Explains how AI is controlled","detail_words":"Names an area"}},{"slug":"coastal-financial-corp","name":"Coastal Financial Corp","state":"WA","size_group":"$1B to $50B","max_detail":2,"quote":{"passage_id":"0001437958-26-000013-35c03e9e5370","quote":"We currently use, and may in the future evaluate or implement, artificial intelligence (“AI”), automation, and similar technologies to support certain internal processes or business functions.","link":"https://www.sec.gov/Archives/edgar/data/1437958/000143795826000013/ck1437958-20251231.htm#:~:text=We%20currently%20use%2C%20and%20may%20in%20the%20future,and%20regulations%20could%20be%20adversely%20affected.","mention_words":"Using AI now","detail_words":"Names an area"}},{"slug":"commercial-bancgroup-inc","name":"Commercial Bancgroup, Inc.","state":"TN","size_group":"$1B to $50B","max_detail":2,"quote":{"passage_id":"0001213900-26-033659-a50fbd556d76","quote":"Our adoption of AI for limited internal use has increased our efficiency, and we expect to continue to adopt such tools as appropriate. In addition, we expect our third-party vendors and service providers to increasingly develop and incorporate AI into their product offerings","link":"https://www.sec.gov/Archives/edgar/data/1981546/000121390026033659/ea0282863-10k_commercial.htm#:~:text=Our%20adoption%20of%20AI%20for%20limited%20internal%20use,to%20which%20we%20are%20a%20party.","mention_words":"Sees AI as a risk","detail_words":"Names an area"}},{"slug":"community-financial-system-inc","name":"Community Financial System, Inc.","state":"NY","size_group":"$1B to $50B","max_detail":2,"quote":{"passage_id":"0001104659-26-021651-156bfc50ae65","quote":"CFSI maintains enterprise-wide AI and Data Governance frameworks designed to promote the accuracy, privacy, security, and responsible use of data and AI across our operations. Executive oversight is provided by the Management Risk Committee and IT Steering Committee","link":"https://www.sec.gov/Archives/edgar/data/723188/000110465926021651/cbu-20251231x10k.htm#:~:text=CFSI%20maintains%20enterprise%2Dwide%20AI%20and%20Data%20Governance%20frameworks,evolving%20regulatory%20requirements%20and%20technological%20advances.","mention_words":"Explains how AI is controlled","detail_words":"Names an area"}},{"slug":"connectone-bancorp-inc","name":"ConnectOne Bancorp, Inc.","state":"NJ","size_group":"$1B to $50B","max_detail":2,"quote":{"passage_id":"0001437749-26-005320-716a17507c64","quote":"we have policies and governance structures prohibiting our employees from using non-approved generative AI applications or websites on the Company or the Bank’s network or devices","link":"https://www.sec.gov/Archives/edgar/data/712771/000143774926005320/cnob20251231c_10k.htm#:~:text=While%20we%20have%20policies%20and%20governance%20structures%20prohibiting,risks%20associated%20with%20using%20AI%20technology.","mention_words":"Explains how AI is controlled","detail_words":"Names an area"}},{"slug":"customers-bancorp-inc","name":"Customers Bancorp, Inc.","state":"PA","size_group":"$1B to $50B","max_detail":2,"quote":{"passage_id":"0001488813-26-000029-f92c1f54c6bc","quote":"In 2025, the Bank launched enterprise-wide training covering foundational AI concepts, responsible-use protocols, and real-world applications tailored to business needs. These initiatives have already generated measurable efficiencies and continue to accelerate the integration of AI into core","link":"https://www.sec.gov/Archives/edgar/data/1488813/000148881326000029/cubi-20251231.htm#:~:text=%E2%80%A2Artificial%20Intelligence%20Proficiency%20and%20Enablement%20%E2%80%93%20The%20Bank,into%20core%20processes%20across%20business%20lines.","mention_words":"Using AI now","detail_words":"Names an area"}},{"slug":"dime-commercial-bancshares-inc-ny","name":"Dime Commercial Bancshares, Inc.","state":"NY","size_group":"$1B to $50B","max_detail":2,"quote":{"passage_id":"0000846617-26-000013-d941289ac670","quote":"Potential AI/ML models, used for credit scoring, fraud detection, customer service, and investment decisions, rely on complex algorithms and vast datasets. Errors, biases, or \"hallucinations\" (generating false information) in these models, or unexpected system failures, could lead to flawed","link":"https://www.sec.gov/Archives/edgar/data/846617/000084661726000013/dcom-20251231x10k.htm#:~:text=%E2%97%8F%20Operational%20%26%20Model%20Risk%3A%20Potential%20AI%2FML%20models%2C,experiences%2C%20impacting%20profitability%20and%20client%20retention.","mention_words":"Sees AI as a risk","detail_words":"Names an area"}},{"slug":"eagle-bancorp-montana-inc","name":"Eagle Bancorp Montana, Inc.","state":"MT","size_group":"$1B to $50B","max_detail":2,"quote":{"passage_id":"0001437749-26-007330-97c0ba7008fe","quote":"Our adoption of artificial intelligence, including generative artificial intelligence, machine learning and similar tools and technologies that collect, aggregate, analyze or generate data or other materials or content (collectively, “AI”), for limited internal use has increased our efficiency","link":"https://www.sec.gov/Archives/edgar/data/1478454/000143774926007330/ebmt20251231_10k.htm#:~:text=Our%20adoption%20of%20artificial%20intelligence%2C%20including%20generative%20artificial,to%20which%20we%20are%20a%20party.","mention_words":"Sees AI as a risk","detail_words":"Names an area"}},{"slug":"fnb-corp-pa","name":"F.N.B. Corporation","state":"PA","size_group":"$50B and above","max_detail":2,"quote":{"passage_id":"0000037808-26-000007-c9c8b8495541","quote":"continually make technological investments to remain competitive in the financial services industry, including the use of AI.","link":"https://www.sec.gov/Archives/edgar/data/37808/000003780826000007/fnb-20251231.htm#:~:text=The%20ability%20to%20deploy%20and%20use%20technology%20effectively,efficiently%20grow%20and%20expand%20customer%20relationships.","mention_words":"Using AI now","detail_words":"Names an area"}},{"slug":"fb-financial-corp","name":"FB Financial Corp","state":"TN","size_group":"$1B to $50B","max_detail":2,"quote":{"passage_id":"0001649749-26-000012-68cd7058140a","quote":"Our current use of AI is confined to controlled, non‑critical administrative or productivity‑support purposes, such as research assistance, drafting, and data summarization.","link":"https://www.sec.gov/Archives/edgar/data/1649749/000164974926000012/fbk-20251231.htm#:~:text=We%20make%20limited%20use%20of%20artificial%20intelligence%20technologies%2C,third%E2%80%91party%20software%20and%20services%20we%20use.","mention_words":"Using AI now","detail_words":"Names an area"}},{"slug":"finwise-bancorp","name":"Finwise Bancorp","state":"UT","size_group":"Under $1B","max_detail":2,"quote":{"passage_id":"0001856365-26-000006-7e9edad0fc7e","quote":"While we have policies prohibiting our employees from using non-approved generative AI applications or websites on the Company or the Bank’s network, there can be no assurances that our employees will adhere to these policies","link":"https://www.sec.gov/Archives/edgar/data/1856365/000185636526000006/finw-20251231.htm#:~:text=While%20we%20have%20policies%20prohibiting%20our%20employees%20from,sensitive%20client%20information%2C%20with%20AI%20technologies.","mention_words":"Sees AI as a 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technologies.","link":"https://www.sec.gov/Archives/edgar/data/712534/000071253426000022/frme-20251231.htm#:~:text=The%20evolving%20legal%2C%20regulatory%2C%20and%20compliance%20framework%20for,protections%20with%20respect%20to%20these%20matters.","mention_words":"Sees AI as a risk","detail_words":"Names an area"}},{"slug":"five-star-bancorp","name":"Five Star Bancorp","state":"CA","size_group":"$1B to $50B","max_detail":2,"quote":{"passage_id":"0001628280-26-012724-805ce15f06c0","quote":"Our adoption of artificial intelligence, including generative artificial intelligence, machine learning, and similar tools and technologies that collect, aggregate, analyze, or generate data or other materials or content (collectively, “AI”), for limited internal use has increased our efficiency","link":"https://www.sec.gov/Archives/edgar/data/1275168/000162828026012724/fsbc-20251231.htm#:~:text=Our%20adoption%20of%20artificial%20intelligence%2C%20including%20generative%20artificial,proprietary%20or%20personal%20information%2C%20and%20violations","mention_words":"Sees AI as a risk","detail_words":"Names an area"}},{"slug":"glacier-bancorp-inc","name":"Glacier Bancorp, Inc.","state":"MT","size_group":"$1B to $50B","max_detail":2,"quote":{"passage_id":"0000868671-26-000023-e7c61c0b1444","quote":"emerging risks from the use of applications that may rely on artificial intelligence","link":"https://www.sec.gov/Archives/edgar/data/868671/000086867126000023/gbci-20251231.htm#:~:text=We%20use%20models%20and%20strategies%20to%20forecast%20losses%2C,artificial%20intelligence.%20Our%20models%20and%20strategies","mention_words":"Sees AI as a risk","detail_words":"Names an area"}},{"slug":"goldman-sachs-group-inc","name":"Goldman Sachs Group","state":"NY","size_group":"$50B and 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to","link":"https://www.sec.gov/Archives/edgar/data/706129/000070612926000024/hbnc-20251231.htm#:~:text=Our%20adoption%20of%20artificial%20intelligence%2C%20including%20generative%20artificial,on%20our%20business%20and%20financial%20results.","mention_words":"Sees AI as a risk","detail_words":"Names an area"}},{"slug":"huntington-bancshares-inc-md","name":"Huntington Bancshares Inc","state":"OH","size_group":"$50B and above","max_detail":2,"quote":{"passage_id":"0000049196-26-000015-e4bad92d8c49","quote":"an Artificial Intelligence Risk Committee","link":"https://www.sec.gov/Archives/edgar/data/49196/000004919626000015/hban-20251231.htm#:~:text=To%20govern%20operational%20risks%2C%20we%20have%20an%20Operational,and%20our%20Audit%20Committee%2C%20as%20appropriate.","mention_words":"Explains how AI is controlled","detail_words":"Names an area"}},{"slug":"international-bancshares-corp","name":"International Bancshares Corp","state":"TX","size_group":"$1B to 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that are based on biased, incomplete, and/or inaccurate datasets","link":"https://www.sec.gov/Archives/edgar/data/720005/000072000525000093/rjf-20250930.htm#:~:text=We%20use%2C%20develop%2C%20and%20incorporate%20within%20our%20technology,use%20AI%20and%20machine%20learning%20technologies.","mention_words":"Sees AI as a risk","detail_words":"Names an area"}},{"slug":"renasant-corp","name":"Renasant Corp","state":"MS","size_group":"$1B to $50B","max_detail":2,"quote":{"passage_id":"0000715072-26-000017-9ffb9fd1f438","quote":"a new back-office process or procedure (each of which may involve the incorporation of AI technologies), the implications to the Company’s information security are required to be considered.","link":"https://www.sec.gov/Archives/edgar/data/715072/000071507226000017/rnst-20251231.htm#:~:text=a%20new%20back%2Doffice%20process%20or%20procedure%20%28each%20of,Company%E2%80%99s%20overall%20enterprise%20risk%20management%20program.","mention_words":"Explains how AI is 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Our ability to manage artificial intelligence related risk is therefore partially dependent on the controls, governance and resilience of","link":"https://www.sec.gov/Archives/edgar/data/719220/000071922026000030/stba-20251231.htm#:~:text=We%20are%20dependent%20for%20the%20majority%20of%20our,our%20business%20and%20results%20of%20operations.","mention_words":"Sees AI as a risk","detail_words":"Names an area"}},{"slug":"santander-holdings-usa-inc","name":"Santander Holdings USA, Inc.","state":"MA","size_group":"$50B and above","max_detail":2,"quote":{"passage_id":"0000811830-26-000005-5d9dccf5971c","quote":"We utilize AI and continue to explore additional uses of AI in connection with our businesses, products and services. However, AI solutions, such as those provided by third parties, may expose us to risks including, without limitation, inadequacies in the AI service that results in false or","link":"https://www.sec.gov/Archives/edgar/data/811830/000081183026000005/sov-20251231.htm#:~:text=%E2%80%A2We%20use%20AI%2C%20which%20could%20expose%20us%20to,reputational%20harm%20and%20other%20adverse%20impacts.","mention_words":"Sees AI as a risk","detail_words":"Names an area"}},{"slug":"sierra-bancorp","name":"Sierra Bancorp","state":"CA","size_group":"$1B to $50B","max_detail":2,"quote":{"passage_id":"0001104659-26-021479-91f09c4c92c0","quote":"the Company’s deployment of AI at this time is generally limited to fraud detection or prevention; we continue to evaluate whether to implement additional AI tools, or agentic AI, in certain limited capacities","link":"https://www.sec.gov/Archives/edgar/data/1130144/000110465926021479/bsrr-20251231x10k.htm#:~:text=We%20are%20subject%20to%20risks%20associated%20with%20the,in%20certain%20limited%20capacities%2C%20taking%20into","mention_words":"Using AI now","detail_words":"Names an area"}},{"slug":"southstate-bank-corp","name":"SouthState Bank Corp","state":"FL","size_group":"$50B and above","max_detail":2,"quote":{"passage_id":"0001104659-26-017884-f8d8923ab9ff","quote":"We have adopted a formal AI Strategy and are making focused investments in AI tools and automation and other technology solutions to improve both our customer facing and back-office services for internal efficiencies","link":"https://www.sec.gov/Archives/edgar/data/764038/000110465926017884/ssb-20251231x10k.htm#:~:text=In%20addition%20to%20serving%20clients%20better%2C%20investments%20in%2C,attract%20new%20customers%20in%20the%20future.","mention_words":"Testing or planning AI","detail_words":"Names an area"}},{"slug":"state-street-corp","name":"State Street Corp","state":"MA","size_group":"$50B and above","max_detail":2,"quote":{"passage_id":"0000093751-26-000124-9f8b58ccadcf","quote":"All regulatory capital calculation models, including any artificial intelligence and machine learning models, must comply with the model risk management framework and corresponding policies.","link":"https://www.sec.gov/Archives/edgar/data/93751/000009375126000124/stt-20251231.htm#:~:text=ERM%E2%80%99s%20MRM%20group%20is%20responsible%20for%20defining%20the,status%20and%20committee%2Dlevel%20review%20and%20challenge.","mention_words":"Explains how AI is controlled","detail_words":"Names an area"}},{"slug":"stock-yards-bancorp-inc","name":"Stock Yards Bancorp, Inc.","state":"KY","size_group":"$1B to $50B","max_detail":2,"quote":{"passage_id":"0001437749-26-005830-9d375b1a0f16","quote":"While we have established programs to manage our increasing exposure to AI, including processes for monitoring related risks, managing third party relationships, incident response, as well as employee awareness and education","link":"https://www.sec.gov/Archives/edgar/data/835324/000143774926005830/sybt20251231_10k.htm#:~:text=We%2C%20or%20our%20third%2Dparty%20vendors%2C%20clients%20or%20counterparties,financial%20condition%20and%20results%20of%20operations.","mention_words":"Sees AI as a risk","detail_words":"Names an area"}},{"slug":"synchrony-financial","name":"Synchrony Financial","state":"CT","size_group":"$50B and above","max_detail":2,"quote":{"passage_id":"0001601712-26-000006-69db5666b654","quote":"Training topics include social engineering (such as phishing), AI, including AI-related threats, and outbound data sharing.","link":"https://www.sec.gov/Archives/edgar/data/1601712/000160171226000006/syf-20251231.htm#:~:text=%E2%80%A2Training%20and%20Education%3A%20Our%20information%20security%20program%20is,the%20evolving%20information%20security%20risk%20landscape.","mention_words":"Explains how AI is controlled","detail_words":"Names an area"}},{"slug":"truist-financial-corp","name":"Truist Financial Corp","state":"NC","size_group":"$50B and above","max_detail":2,"quote":{"passage_id":"0000092230-26-000030-27cd95f628f2","quote":"Truist’s AI program is foundationally based on the National Institute of Standards and Technology AI Risk Management Framework Core, which provides outcomes and actions that enable dialogue, understanding, and activities to manage AI risks and develop trustworthy AI systems.","link":"https://www.sec.gov/Archives/edgar/data/92230/000009223026000030/tfc-20251231.htm#:~:text=Truist%E2%80%99s%20AI%20program%20is%20foundationally%20based%20on%20the,Board%2C%20the%20BRC%2C%20and%20the%20BTC.","mention_words":"Explains how AI is controlled","detail_words":"Names an area"}},{"slug":"univest-financial-corp","name":"UNIVEST FINANCIAL Corp","state":"PA","size_group":"$1B to $50B","max_detail":2,"quote":{"passage_id":"0000102212-26-000012-74c42782f119","quote":"We utilize certain AI/ML models provided by third-party vendors, including models used for credit scoring and fraud detection, and may use other AI/ML models in the future.","link":"https://www.sec.gov/Archives/edgar/data/102212/000010221226000012/uvsp-20251231.htm#:~:text=%E2%80%A2Operational%20and%20Model%20Risk%3A%20AI%2FML%20models%20may%20rely,other%20AI%2FML%20models%20in%20the%20future.","mention_words":"Sees AI as a risk","detail_words":"Names an area"}},{"slug":"umb-financial-corp","name":"Umb Financial Corp","state":"MO","size_group":"$50B and above","max_detail":2,"quote":{"passage_id":"0001193125-26-076496-090827fb0e25","quote":"The Company has also established a Technology, Operations, Privacy and Security Committee (TOPS) to oversee the business continuity and resilience, corporate security, fraud, information security, privacy, information technology, and third-party risk management (including emerging technology (e.g.,","link":"https://www.sec.gov/Archives/edgar/data/101382/000119312526076496/umbf-20251231.htm#:~:text=The%20CISO%2FCPO%20has%20more%20than%20two%20decades%20of,of%20leaders%20experienced%20in%20managing%20risk.","mention_words":"Explains how AI is controlled","detail_words":"Names an area"}},{"slug":"union-bankshares-inc","name":"Union Bankshares Inc","state":"VT","size_group":"$1B to $50B","max_detail":2,"quote":{"passage_id":"0000706863-26-000029-eb1851537969","quote":"We are piloting and selectively using artificial intelligence and machine learning technologies in limited, primarily internal functions, which exposes us to operational, regulatory, and reputational risks that could adversely affect our business.","link":"https://www.sec.gov/Archives/edgar/data/706863/000070686326000029/unb-20251231.htm#:~:text=We%20are%20piloting%20and%20selectively%20using%20artificial%20intelligence,that%20could%20adversely%20affect%20our%20business.","mention_words":"Using AI now","detail_words":"Names an area"}},{"slug":"unity-bancorp-inc-nj","name":"Unity Bancorp Inc","state":"NJ","size_group":"$1B to $50B","max_detail":2,"quote":{"passage_id":"0000920427-26-000012-df720ec7604c","quote":"We use, and expect to continue to expand our use of, artificial intelligence and machine learning technologies, including generative artificial intelligence models, in our operations and through third-party vendors.","link":"https://www.sec.gov/Archives/edgar/data/920427/000092042726000012/unty-20251231x10k.htm#:~:text=We%20use%2C%20and%20expect%20to%20continue%20to%20expand,consumer%20protection%20and%20fair%20lending%20requirements.","mention_words":"Using AI now","detail_words":"Names an area"}},{"slug":"valley-national-bancorp","name":"Valley National Bancorp","state":"NY","size_group":"$50B and above","max_detail":2,"quote":{"passage_id":"0000714310-26-000017-f4815a359df3","quote":"we have implemented an AI governance, oversight, and strategic facilitation function that includes a risk assessment of internal and vendor AI solutions, due diligence, model validation, and controls, as well as detailed guidelines and policies designed to promote responsible, secure, and ethical","link":"https://www.sec.gov/Archives/edgar/data/714310/000071431026000017/vly-20251231.htm#:~:text=In%20an%20effort%20to%20adopt%20such%20tools%20responsibility,to%20which%20we%20are%20a%20party.","mention_words":"Explains how AI is controlled","detail_words":"Names an area"}},{"slug":"wintrust-financial-corp","name":"Wintrust Financial Corp","state":"IL","size_group":"$50B and above","max_detail":2,"quote":{"passage_id":"0001015328-26-000007-50ebb9ab8fb0","quote":"We may selectively incorporate AI technology in certain business processes, fraud detection, services or products, including technologies that process sensitive financial and/or personal data.","link":"https://www.sec.gov/Archives/edgar/data/1015328/000101532826000007/wtfc-20251231.htm#:~:text=The%20use%20of%20artificial%20intelligence%20%28%E2%80%9CAI%E2%80%9D%29%20in%20the,financial%20condition%20or%20results%20of%20operations.","mention_words":"Sees AI as a risk","detail_words":"Names an area"}},{"slug":"zions-bancorporation-national-association-ut","name":"Zions Bancorporation, National Association","state":"UT","size_group":"$50B and above","max_detail":2,"quote":{"passage_id":"0000109380-26-000046-ff74e93e4d2b","quote":"We have implemented a framework for the responsible use and oversight of AI, guided by established policies and standards, and overseen by the Data and AI Governance Committee.","link":"https://www.sec.gov/Archives/edgar/data/109380/000010938026000046/zions-20251231.htm#:~:text=We%20have%20implemented%20a%20framework%20for%20the%20responsible,adherence%20to%20regulatory%20and%20ethical%20standards.","mention_words":"Explains how AI is controlled","detail_words":"Names an area"}},{"slug":"banner-corp","name":"Banner Corp","state":"WA","size_group":"$1B to $50B","max_detail":1,"quote":{"passage_id":"0000946673-26-000009-9dcc41f81ba6","quote":"Our current and future uses of Artificial Intelligence (AI) and other emerging technologies may create additional risks.","link":"https://www.sec.gov/Archives/edgar/data/946673/000094667326000009/banr-20251231.htm#:~:text=Our%20current%20and%20future%20uses%20of%20Artificial%20Intelligence,emerging%20technologies%20may%20create%20additional%20risks.","mention_words":"Sees AI as a risk","detail_words":"General"}},{"slug":"home-bancshares-inc","name":"Home Bancshares Inc","state":"AR","size_group":"$1B to $50B","max_detail":1,"quote":{"passage_id":"0001331520-26-000051-de264d5edd08","quote":"New and evolving AI use, including generative AI, may make us susceptible to uncertain risks and may require additional investment to develop responsible use frameworks.","link":"https://www.sec.gov/Archives/edgar/data/1331520/000133152026000051/homb-20251231.htm#:~:text=The%20financial%20services%20industry%20continues%20to%20undergo%20rapid,results%20of%20operations%20and%20future%20prospects.","mention_words":"Sees AI as a risk","detail_words":"General"}},{"slug":"investar-holding-corp","name":"Investar Holding Corp","state":"LA","size_group":"$1B to $50B","max_detail":1,"quote":{"passage_id":"0001437749-26-008446-925f6e8da2c5","quote":"Our failure to effectively implement new technologies including artificial intelligence could adversely affect our operations and financial condition.","link":"https://www.sec.gov/Archives/edgar/data/1602658/000143774926008446/istr20251231_10k.htm#:~:text=Our%20failure%20to%20effectively%20implement%20new%20technologies%20including,affect%20our%20operations%20and%20financial%20condition.","mention_words":"Sees AI as a risk","detail_words":"General"}},{"slug":"isabella-bank-corp","name":"Isabella Bank Corp","state":"MI","size_group":"$1B to $50B","max_detail":1,"quote":{"passage_id":"0000842517-26-000069-98ab42e589ab","quote":"Emerging technologies, such as artificial intelligence, may further increase the risk of a cyber-attack.","link":"https://www.sec.gov/Archives/edgar/data/842517/000084251726000069/isba-20251231.htm#:~:text=The%20introduction%20of%20new%20products%20and%20services%20can,effect%20on%20our%20business%20and%20reputation.","mention_words":"Sees AI as a risk","detail_words":"General"}},{"slug":"northpointe-bancshares-inc","name":"Northpointe Bancshares Inc","state":"MI","size_group":"$1B to $50B","max_detail":1,"quote":{"passage_id":"0001336706-26-000020-be1177e9b265","quote":"including but not limited to artificial intelligence, which may be used by threat actors to perpetuate cyberattacks","link":"https://www.sec.gov/Archives/edgar/data/1336706/000133670626000020/npb-20251231.htm#:~:text=The%20techniques%20used%20to%20obtain%20unauthorized%2C%20improper%20or,members%2C%20vendors%2C%20clients%20and%20loan%20applicants.","mention_words":"Sees AI as a risk","detail_words":"General"}}]}