FINW · UT · Small bank (Under $1B)
Total assets of FDIC-insured bank subsidiaries: $1B at the end of 2025
Filings on the SEC website · This bank on Bankgraph
| Report year | Using or planning AI | Explains how AI is controlled | Sees AI as a risk | Other mentions |
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| In the 2025 report | This bank | Banks of its size |
|---|---|---|
| Using AI now | Yes | 1 of 6 (17%) |
| Explains how AI is controlled | Yes | 2 of 6 (33%) |
| Sees AI as a risk | Yes | 4 of 6 (67%) |
| Mentions generative AI | Yes | 1 of 6 (17%) |
| Mentions AI agents | Yes | 1 of 6 (17%) |
9 passages new in the 2025 report, 0 passages from the 2024 report no longer there. The most specific passage is more detailed than last year.
The Tallied platform is a fully cloud-native, SOC2 certified and API-first operating system for modern credit cards. It spans application and decisioning engines, card issuance-processing, a rewards engine, AI-powered fraud scoring, dispute handling and compliance self-audit capabilities. Built by a seasoned issuer-processing team and developed with substantial
•The inability to keep pace with rapid technological changes or implement new technology effectively, including the development and use of artificial intelligence;
We rely on a combination of copyright, trademark, trade secret laws and confidentiality provisions to establish and protect our intellectual property rights, including our proprietary technologies and our analytic models. If we fail to successfully maintain, protect and enforce our intellectual property rights, our competitive position could suffer. Similarly, if we were to infringe on the intellectual property rights of others, our competitive position could suffer. Third parties may challenge, invalidate, circumvent, infringe or misappropriate our intellectual property, or such intellectual property may not be sufficient to permit us to take advantage of current market trends or otherwise to provide competitive advantages, which could result in costly redesign efforts, discontinuance of certain product or service offerings or other competitive harm. We may also be required to spend significant resources to monitor and police our intellectual property rights. Others, including our competitors, may independently develop similar analytic model technology, duplicate our products or services or design around our intellectual property, and in such cases we may not be able to assert our intellectual property rights against such parties. Further, our contractual arrangements may not effectively prevent disclosure of our confidential information or provide an adequate remedy in the event of unauthorized disclosure of our confidential or proprietary information. We may have to litigate to enforce or determine the scope and enforceability of our intellectual property rights, trade secrets and know-how, which could be time-consuming and expensive, could cause a diversion of resources and may not prove successful. The loss of intellectual property protection or the inability to obtain rights with respect to third party intellectual property could harm our business and ability to compete. In addition, because of the rapid pace of technological change in our industry, including the use of AI, aspects of our business and our products and services rely on technologies developed or licensed by third parties, and we may not be able to obtain or continue to obtain licenses and technologies from these third parties on reasonable terms or at all.
Many of our larger competitors have substantially greater resources to invest in technological improvements. Third parties upon which we rely for our technology needs may not be able to develop, on a cost-effective basis, systems that will enable us to keep pace with such developments. As a result, our larger competitors may be able to offer additional or superior products compared to those that we will be able to provide, which would put us at a competitive disadvantage. We may lose customers seeking new technology-driven products and services to the extent we are unable to provide such products and services. The ability to keep pace with technological change is important and the failure to do so could adversely affect our business, financial condition and results of operations. The use of AI in the banking industry is developing and growing. Customer demand may cause us and others to offer products or services incorporating AI. As with many developing technologies, artificial intelligence presents risks and challenges that could affect its further development, adoption, and use, and therefore our business. Our future success will depend, in part, upon our ability to invest in and use appropriate technology, which may include AI. To effectively make such investments, we may need to expend significant financial, human, and other resources. However, we may not be able to implement AI in an effective or timely way, thus adversely impacting our operations. This may also adversely impact our ability to compete with financial institutions which have greater resources to invest in such technological improvements. Ultimately, any AI we develop or use may be flawed. If our use of AI, or its use by third parties with which we do business or otherwise interact, is deficient, biased, or inaccurate, or compromises customer privacy or implicates other ethics issues, we could be subject to competitive harm, potential legal liability, and brand or reputational harm.
The development and use of artificial intelligence present risks and challenges that may adversely impact our business.
We selectively employ AI through productivity tools, third-party solutions, and internal systems. We use generative AI for certain tasks like document drafting and data analysis, with an implementation of strict controls to protect customer data. Third-party AI assists us in cybersecurity, fraud detection, and code review, while our own agents handle compliance, policy analysis, and workflow optimization. A disciplined AI adoption approach remains the most effective strategy for us. However, the advances in generative AI are opening new opportunities for efficiency and automation. We are actively exploring opportunities to broaden the deployment of these capabilities across our Company to drive efficiency and long term value, with a disciplined focus on safeguarding sensitive data through secure and controlled implementation. However, the continued development and use of AI presents a number of risks and challenges to our business.
The legal and regulatory environment relating to AI is uncertain and rapidly evolving and includes regulation targeted specifically at AI as well as provisions in intellectual property, privacy, consumer protection, employment and other laws applicable to the use of AI. These evolving laws and regulations could require changes in our implementation of AI technology and increase our compliance costs and the risk of non-compliance, including in relation to data privacy and security laws, which mandate the protection of consumer financial information.
AI models, particularly generative AI models, may produce output or take action that is incorrect, that results in the release of private, confidential or proprietary information, that reflects biases included in the data on which they are trained, that produces output that is, or is perceived to be, discriminatory or unfair, that infringes on the intellectual property rights of others, or that is otherwise harmful.
Similar wording appears in 21 other banks' reports.
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 or that such policies will be effective in mitigating the risks associated with using AI technology. Furthermore, although we have not authorized the use of any AI tools with personally identifiable or nonpublic information, employees may intentionally or inadvertently violate our policy by using personally identifiable or nonpublic information, including sensitive client information, with AI technologies.
Since personally identifiable or nonpublic information may be used with such technologies, these technologies are capable of generating output that improperly discloses such personally identifiable or nonpublic information. The use of personally identifiable or nonpublic information could result in a violation of certain laws, including data privacy laws and the data privacy and security laws, exposing us to legal liability or regulatory penalties. Furthermore, we may rely on AI models developed by third parties, and, to that extent, would be dependent in part on the manner in which those third parties develop and train their models, including risks arising from the inclusion of any unauthorized material in the training data
24 • 2017: Began using API to connect with Strategic Program service providers • 2018: Used data to analyze retention of selected Strategic Program loans and Partner Performance • 2020: Created new enterprise data warehouse to more efficiently aggregate and normalize origination and servicing data 2016 Strategic Program Service Providers: 1 2017 API v1 Strategic Program Service Providers: 4 2018- 2019 Manual credit insights Strategic Program Service Providers: 7-9 API v1 2019- 2020 Manual credit insights Strategic Program Service Providers: 9 API v1 2021- 2022 Manual credit insights Strategic Program Service Providers: 8 API v1 Enterprise Data Warehouse 2022- 2023 Manual credit insights Strategic Program Service Providers: 11+ API v1 Enterprise Data Warehouse 2023+ Manual credit insights Strategic Program Service Providers: 11+ API v1 Enterprise Data Warehouse ML / AI Analytics & BI Capability The acquisition of millions of loan origination and servicing data points creates valuable data insights that drive more informed data driven decision-making across asset classes, enables more efficient product launches and post- launch program oversight Technology Platform – Buildout Payments via API (Payments Hub) MPL API v2 (BaaS Platform) Enterprise Data Warehouse API v2 (BaaS Platform) API v2 (BaaS Platform) ML + AI Analytics & BI Capability • 2021: Upgraded MPL API Capabilities and Started planning new MPL API platform • 2022: Started planning Building new MPL API to include more BaaS platform features • 2023: Launch new MPL API platform and Launch new API driven Payments Hub and start onboarding new BaaS Partners • 2024-5: Migrate & add new MPL API/ BaaS platform Fintech’s and expand features and functionality
FinView™ Analytics Platform: Buildout Drives Continued Scale Near-term strategic priority; timing of product development dependent on several factors, including timing for new hires 2017: Began using API to connect with Strategic Program service providers 2018: FinView™ used to analyze retention of selected Strategic Program loans 2020: Enhanced enterprise data warehouse to more efficiently capture loan origination and servicing data 2021: Continued build out of FinView’s™ business analytics module; building an updated version of its API 2016 Strategic Program Service Providers: 1 2017 API v1 Strategic Program Service Providers: 4 2018 Manual credit insights Strategic Program Service Providers: 7 API v1 2019 Manual credit insights Strategic Program Service Providers: 9 API v1 2020 Manual credit insights Strategic Program Service Providers: 8 API v1 Enterprise Data Warehouse 2021 Manual credit insights Strategic Program Service Providers: 11 API v1 Upgrade Enterprise Data Warehouse Start Development API v2 2022 Manual credit insights Strategic Program Service Providers: 11+ API v1 Enterprise Data Warehouse Continued Development API v2 Business Intelligence Analytics Machine Learning and AI The compilation of millions of loan origination and servicing data points creates deep insights that drive more informed decision-making across asset classes, and enables more efficient product launches 2023+ Manual credit insights Strategic Program Service Providers: 11+ API v1 Enterprise Data Warehouse Launch API v2 Business Intelligence Analytics Machine Learning and AI
•our ability to keep pace with rapid technological changes in the industry or implement new technology effectively including development of applications utilizing artificial intelligence;
These forward-looking statements are based on management assumptions and involve risks and uncertainties that are subject to change based on various important factors, some of which are beyond the Company’s control. Numerous competitive, economic, regulatory, legal and technological events and factors, among others, could cause the Company’s actual results to differ materially from those indicated in these forward-looking statements, including: the success of the financial technology and banking-as-a-service industries, as well as the continued evolution of the regulation of these industries; the Company’s ability to maintain and grow its relationships with its service providers and reliance on such providers to comply with regulatory regimes; the Company’s ability to keep pace with rapid technological changes in the industry or implement new technology effectively, in particular the recent advancements in artificial intelligence and the risks that such technology presents; ability to effectively manage and remediate system failure or cybersecurity breaches of the Company’s network security; the Company’s ability to measure and manage its credit risk effectively and any deterioration of the business and economic conditions in the Company’s primary market areas; the adequacy of the Company’s allowance for credit losses; changes in Small Business Administration rules, regulations and loan products and the existing regulatory framework for brokered deposits; higher inflation and its impacts; the effects of changes in U.S. trade policies, including the imposition of tariffs and retaliatory tariffs on its trading partners; the value of collateral securing the Company’s loans; the Company’s levels of nonperforming assets; the potential for negative consequences resulting from regulatory violations, investigations and examinations, including potential supervisory actions, the assessment of fines and penalties, the imposition of sanctions, the need to undertake remedial actions and possible damage to the Company’s reputation; natural disasters and adverse weather, acts of terrorism, pandemics, an outbreak of hostilities or other international or domestic calamities, including the ongoing conflicts in Iran and Middle East that can increase levels of political and economic unpredictability, contribute to rising energy and commodity prices, and increase the volatility of financial markets; anticipated benefits of new lines of business that the Company may enter or investments or acquisitions the Company may make that are not realized within the expected time frame or at all, including the Company’s ability to manage integration costs; further negative ratings outlooks or downgrades of the long-term credit rating of the United States; and potential government shutdowns and other political impasses, including with respect to the debt ceiling and the federal budget of the United States.
These forward-looking statements are based on management assumptions and involve risks and uncertainties that are subject to change based on various important factors, some of which are beyond the Company’s control. Numerous competitive, economic, regulatory, legal and technological events and factors, among others, could cause the Company’s actual results to differ materially from those indicated in these forward-looking statements, including: the success of the financial technology and banking-as-a-service industries, as well as the continued evolution of the regulation of these industries; the Company’s ability to maintain and grow its relationships with its service providers and reliance on such providers to comply with regulatory regimes; the Company’s ability to keep pace with rapid technological changes in the industry or implement new technology effectively, in particular the recent advancements in artificial intelligence and the risks that such technology presents; ability to effectively manage and remediate system failure or cybersecurity breaches of the Company’s network security; the Company’s ability to measure and manage its credit risk effectively and any deterioration of the business and economic conditions in the Company’s primary market areas; the adequacy of the Company’s allowance for credit losses; changes in Small Business Administration rules, regulations and loan products and the existing regulatory framework for brokered deposits; higher inflation and its impacts; the effects of changes in U.S. trade policies, including the imposition of tariffs and retaliatory tariffs on its trading partners; the value of collateral securing the Company’s loans; the Company’s levels of nonperforming assets; the potential for negative consequences resulting from regulatory violations, investigations and examinations, including potential supervisory actions, the assessment of fines and penalties, the imposition of sanctions, the need to undertake remedial actions and possible damage to the Company’s reputation; natural disasters and adverse weather, acts of terrorism,
•our ability to keep pace with rapid technological changes in the industry or implement new technology effectively including development of applications utilizing artificial intelligence;
•our ability to keep pace with rapid technological changes in the industry or implement new technology effectively including development of applications utilizing artificial intelligence;