Topics

Generative AI

146 of 270 banks (54%) in their 2025 annual reports. Banks that mention generative AI or large language models.

The banks

• Bank of Hawaii Corp
  HI · Mid-size bank ($1B to $50B)

  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.

  Using AI nowRead it in the report
• Bank of Marin Bancorp
  CA · Mid-size bank ($1B to $50B)

  The Company’s deployment of artificial intelligence at this time is generally limited to internally focused, assistive productivity tools such as Microsoft Copilot.

  Using AI nowRead it in the report
• Fifth Third Bancorp
  OH · Large bank ($50B and above)

  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

  Using AI nowRead it in the report
• First Financial Corp
  IN · Mid-size bank ($1B to $50B)

  as technology, including the increasing use of artificial intelligence, machine learning, large language models, artificial intelligence agents, generative artificial intelligence, and other similar technologies (collectively referred to as “AI”), and cyberattacks change over time, we may be

  Sees AI as a riskRead it in the report
• U.S. Bancorp
  MN · Large bank ($50B and above)

  The adoption and rapid growth of new technologies, including generative AI, cryptocurrencies, stablecoins, other digital assets, blockchain and other distributed ledger technologies, have required, and will continue to require, the Company to incur substantial expense to adapt its systems

  Sees AI as a riskRead it in the report
• Acnb Corp
  PA · Mid-size bank ($1B to $50B)

  ACNB’s customers and potential customers may express adverse opinions concerning its use of AI and machine learning that could result in brand or reputational harm, competitive harm, or legal liability.

  Sees AI as a riskRead it in the report
• Ally Financial Inc.
  MI · Large bank ($50B and above)

  The deployment and use of AI within our businesses and operations may present new or increased legal, regulatory, reputational, operational and other risks that further complicate model risk management, data security and privacy protection, data governance and management, and third-party risk

  Sees AI as a riskRead it in the report
• American Express Co
  NY · Large bank ($50B and above)

  We also continue to explore ways to deploy new and developing technologies to enhance our payments platform and customer experience, such as uses for generative artificial intelligence (AI) and the integration of our products and services in agentic commerce.

  Testing or planning AIRead it in the report
• Ameris Bancorp
  GA · Mid-size bank ($1B to $50B)

  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

  Sees AI as a riskRead it in the report
• Arrow Financial Corp
  NY · Mid-size bank ($1B to $50B)

  In addition to risks associated with direct adoption of AI applications by us, we face the risk of associates utilizing unauthorized publicly sourced AI tools to complete business functions.

  Sees AI as a riskRead it in the report
• Associated Banc-Corp
  WI · Mid-size bank ($1B to $50B)

  States have started to regulate the use of AI technologies. Of note, the California Privacy Protection Agency has finalized regulations under the CCPA regarding the use of automated decision making.

  Sees AI as a riskRead it in the report
• Atlantic Union Bankshares Corp
  VA · Mid-size bank ($1B to $50B)

  The use of artificial intelligence models developed by third parties introduces risks related to how those models are developed, trained, and deployed, including unauthorized material in training data and limited visibility into risk mitigation steps.

  Sees AI as a riskRead it in the report
• Avidbank Holdings, Inc.
  CA · Mid-size bank ($1B to $50B)

  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

  Sees AI as a riskRead it in the report
• Banc of California, Inc.
  CA · Mid-size bank ($1B to $50B)

  Generative artificial intelligence is further increasing risks in this area, including by making fraud detection more difficult, particularly with detection devices that use voice recognition or authentication.

  Sees AI as a riskRead it in the report
• Bancorp, Inc.
  DE · Mid-size bank ($1B to $50B)

  The developments and use of AI presents several potential risks and challenges to our business. The legal and regulatory environment relating to AI is uncertain and rapidly evolving in the U.S. and internationally

  Sees AI as a riskRead it in the report
• Bank of New York Mellon Corp
  NY · Large bank ($50B and above)

  Model Risk Management’s framework includes use cases employing artificial intelligence, including large language models, and Model Risk Management is among the functions integrated into the Company’s broader, cross-functional artificial intelligence risk management framework.

  Explains how AI is controlledRead it in the report
• Bok Financial Corp
  OK · Large bank ($50B and above)

  Each initiative is subject to a specific internal governance process designed to assess risks related to data quality, bias, regulatory compliance, and ethical considerations.

  Sees AI as a riskRead it in the report
• Byline Bancorp, Inc.
  IL · Mid-size bank ($1B to $50B)

  address material risks from potential cybersecurity threats, including threats utilizing generative AI, and to facilitate the governance and oversight of cybersecurity risks

  Explains how AI is controlledRead it in the report
• C & F Financial Corp
  VA · Mid-size bank ($1B to $50B)

  We are evaluating potential use cases across all subsidiaries and departments for the prudent adoption of Artificial Intelligence (AI) including robotic process automation, generative and agentic AI, and machine learning tools.

  Testing or planning AIRead it in the report
• CVB Financial Corp
  CA · Mid-size bank ($1B to $50B)

  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.

  Explains how AI is controlledRead it in the report
• Capital City Bank Group Inc
  FL · Mid-size bank ($1B to $50B)

  models, particularly generative or agentic AI models, may produce outputs or

  Sees AI as a riskRead it in the report
• Capital One Financial Corp
  VA · Large bank ($50B and above)

  we use models and AI in certain processes and may expand our use of AI in additional processes in the future. Some examples may include determining the pricing of products, identifying potentially fraudulent transactions, grading loans, extending credit

  Using AI nowRead it in the report
• Chain Bridge Bancorp Inc
  VA · Mid-size bank ($1B to $50B)

  These AI technologies assist in drafting documents and communications, conducting research, and enhancing operational efficiency.

  Using AI nowRead it in the report
• Citigroup Inc
  NY · Large bank ($50B and above)

  Citi has used AI and machine learning tools for many years and has more recently begun to broadly deploy Generative AI, including within its technology platforms and services.

  Using AI nowRead it in the report
• Citizens Financial Group Inc
  RI · Large bank ($50B and above)

  Evolving technologies, including the introduction of Generative Artificial Intelligence and Large Language Models, and the increased sophistication and activities of organized crime, hackers, terrorists, nation-states, activists, and other external parties present a significant information security

  Sees AI as a riskRead it in the report
• Commercial Bancgroup, Inc.
  TN · Mid-size bank ($1B to $50B)

  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

  Sees AI as a riskRead it in the report
• Community Financial System, Inc.
  NY · Mid-size bank ($1B to $50B)

  the Company’s increasing use of analytics, machine-learning and generative AI introduces additional data and model risks, including threats to data privacy and integrity, biased or incorrect model outputs, exploitation of third-party models or vendors, and automation-enabled escalation of attacks.

  Sees AI as a riskRead it in the report
• ConnectOne Bancorp, Inc.
  NJ · Mid-size bank ($1B to $50B)

  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

  Explains how AI is controlledRead it in the report
• Dime Commercial Bancshares, Inc.
  NY · Mid-size bank ($1B to $50B)

  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

  Sees AI as a riskRead it in the report
• ENB Financial Corp
  PA · Mid-size bank ($1B to $50B)

  Our customers and potential customers may express adverse opinions concerning our use of AI and machine learning that could result in brand or reputational harm, competitive harm, or legal liability.

  Sees AI as a riskRead it in the report
• Eagle Bancorp Montana, Inc.
  MT · Mid-size bank ($1B to $50B)

  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

  Sees AI as a riskRead it in the report
• F.N.B. Corporation
  PA · Large bank ($50B and above)

  We rely heavily on a broad range of quantitative models, advanced analytics, AI, and generative AI technologies across multiple areas of our operations, including credit decisioning, fraud detection, risk monitoring, customer engagement, productivity enhancement and internal operational processes.

  Using AI nowRead it in the report
• FB Financial Corp
  TN · Mid-size bank ($1B to $50B)

  Our current use of AI is confined to controlled, non‑critical administrative or productivity‑support purposes, such as research assistance, drafting, and data summarization.

  Using AI nowRead it in the report
• Finwise Bancorp
  UT · Small bank (Under $1B)

  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

  Sees AI as a riskRead it in the report
• First Bancorp, Inc
  ME · Mid-size bank ($1B to $50B)

  Currently employees have access to generative AI applications for limited productivity and research purposes.

  Using AI nowRead it in the report
• First Busey Corp
  KS · Mid-size bank ($1B to $50B)

  Failure to effectively adopt, integrate, or govern new technologies—including generative AI—may impair Busey’s ability to attract and retain customers, compete with technologically advanced financial firms, or achieve anticipated efficiencies.

  Sees AI as a riskRead it in the report
• First Business Financial Services, Inc.
  WI · Mid-size bank ($1B to $50B)

  There are inherent risks involved in utilizing AI and no assurance can be provided that our or our third-party vendors’ or service providers’ use of AI will enhance our or our third-party vendors’ or service providers’ products or services or produce the intended results.

  Sees AI as a riskRead it in the report
• First Citizens Bancshares Inc
  NC · Large bank ($50B and above)

  The use of AI presents its own unique risks. Third-party development of AI models introduces risks related to how those models are developed, trained, and deployed, including unauthorized material in training data and limited visibility into risk mitigation steps.

  Sees AI as a riskRead it in the report
• First Hawaiian, Inc.
  HI · Mid-size bank ($1B to $50B)

  The development and use of AI present a number of risks and challenges to our business. The legal and regulatory environment relating to AI is uncertain and rapidly evolving, both in the U.S. and internationally

  Sees AI as a riskRead it in the report
• First Interstate Bancsystem Inc
  MT · Mid-size bank ($1B to $50B)

  the legal and regulatory environment relating to emerging technologies such as AI will continue to develop and could increase the cost of doing business, and create compliance risks and potential liability, all which may have a material adverse effect on our financial condition and results of

  Sees AI as a riskRead it in the report
• First Merchants Corp
  IN · Mid-size bank ($1B to $50B)

  This use may expose the Corporation to various risks and potential liabilities, including: enhanced governmental or regulatory scrutiny; litigation; ethical concerns; confidentiality and security risks; intellectual property concerns over data rights and protection

  Sees AI as a riskRead it in the report
• Five Star Bancorp
  CA · Mid-size bank ($1B to $50B)

  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

  Sees AI as a riskRead it in the report
• Goldman Sachs Group
  NY · Large bank ($50B and above)

  as we expand the development and incorporation of AI technologies in our business processes, services or products, including in connection with our OneGS 3.0 initiative, these risks may be heightened.

  Sees AI as a riskRead it in the report
• Hancock Whitney Corp
  MS · Mid-size bank ($1B to $50B)

  AI models, particularly generative AI models, may produce output or take action that is incorrect, that reflects biases included in the data on which they are trained, that results in the release of private, confidential, or proprietary information

  Sees AI as a riskRead it in the report
• Horizon Bancorp Inc
  IN · Mid-size bank ($1B to $50B)

  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”), is limited for internal currently, and we expect to

  Sees AI as a riskRead it in the report
• International Bancshares Corp
  TX · Mid-size bank ($1B to $50B)

  Our ISSP also applies to cybersecurity and data protection risks associated with artificial intelligence, including generative artificial intelligence whether those risks arise from our use of AI solutions or from AI-enabled threats and attack techniques used by malicious actors.

  Explains how AI is controlledRead it in the report
• JPMorgan Chase & Co.
  NY · Large bank ($50B and above)

  The rapid development and deployment of advanced technologies, including generative and agentic AI systems, present a range of risks to JPMorganChase’s businesses and operations

  Sees AI as a riskRead it in the report
• KeyCorp
  OH · Large bank ($50B and above)

  Increased model and generative AI use could expose us to liability or adverse legal or regulatory consequences and harm our reputation and the public perception of our business or the effectiveness of our security measures.

  Sees AI as a riskRead it in the report
• Live Oak Bancshares, Inc.
  NC · Mid-size bank ($1B to $50B)

  We continually evaluate and selectively deploy emerging technologies like artificial intelligence (“AI”), sometimes referred to as AI, and machine learning for incorporation in our business.

  Using AI nowRead it in the report
• MainStreet Bancshares, Inc.
  VA · Mid-size bank ($1B to $50B)

  We have implemented an AI governance function and risk management framework that includes a risk assessment of internal and vendor AI solutions, due diligence, and controls.

  Explains how AI is controlledRead it in the report
• Mechanics Bancorp
  CA · Mid-size bank ($1B to $50B)

  Artificial intelligence, including generative artificial intelligence,

  Sees AI as a riskRead it in the report
• Metropolitan Bank Holding Corp.
  NY · Mid-size bank ($1B to $50B)

  AI development or deployment practices by the Company, our customers, or third-party developers or vendors could result in unintended consequences. For example, AI algorithms could be flawed or may be based on datasets that are inaccurate, biased or insufficient.

  Sees AI as a riskRead it in the report
• Midland States Bancorp, Inc.
  IL · Mid-size bank ($1B to $50B)

  This includes development in areas such as generative artificial intelligence, robotic process automation, process improvement, and data-informed decision-making.

  Using AI nowRead it in the report
• Morgan Stanley
  NY · Large bank ($50B and above)

  We continually review our Cybersecurity Program, and make adjustments where appropriate, to address the evolving cybersecurity threat landscape, including threats arising from new technologies, such as generative artificial intelligence

  Explains how AI is controlledRead it in the report
• NBT Bancorp Inc
  NY · Mid-size bank ($1B to $50B)

  The Company’s use of AI currently varies across platforms, with certain third party systems incorporating AI capabilities into routine business operations. As our adoption and internal development of AI enabled tools continues to evolve, we evaluate these technologies through our established

  Sees AI as a riskRead it in the report
• NewtekOne, Inc.
  FL · Mid-size bank ($1B to $50B)

  we are exposed to risks arising from the use of AI technologies by bad actors to commit fraud and misappropriate funds and to facilitate cyberattacks. Generative AI, if used to perpetrate fraud or launch cyberattacks, could create panic at a particular financial institution

  Sees AI as a riskRead it in the report
• Northern Trust Corp
  IL · Large bank ($50B and above)

  the use of generative AI, a relatively new and emerging technology in the early stages of commercial use, exposes us to additional risks, such as damage to our reputation, competitive position, and business, legal and regulatory risks and additional costs.

  Sees AI as a riskRead it in the report
• Old National Bancorp
  IN · Large bank ($50B and above)

  The use and development of artificial intelligence, including digital employees and digital engineers, by Old National and its third party vendors, clients, counterparties, and other market participants in certain business processes, models, including generative artificial intelligence models

  Sees AI as a riskRead it in the report
• Orange County Bancorp, Inc.
  NY · Mid-size bank ($1B to $50B)

  We are also exposed to risks arising from the use of AI technologies by bad actors to commit fraud and misappropriate funds and to facilitate cyberattacks.

  Sees AI as a riskRead it in the report
• PNC Financial Services Group
  PA · Large bank ($50B and above)

  The techniques used in cyber attacks and breaches change rapidly and are increasingly sophisticated, including through the use of generative AI and deepfakes

  Sees AI as a riskRead it in the report
• Peoples Bancorp of North Carolina Inc
  NC · Mid-size bank ($1B to $50B)

  We have implemented an AI governance function and risk management framework that includes a risk assessment of internal and vendor AI solutions, due diligence, model validation, and controls.

  Sees AI as a riskRead it in the report
• Raymond James Financial Inc
  FL · Large bank ($50B and above)

  ineffective or inadequate AI development or deployment practices by us or third-party vendors could result in unintended consequences such as AI algorithms that produce inaccurate output or that are based on biased, incomplete, and/or inaccurate datasets

  Sees AI as a riskRead it in the report
• Regions Financial Corp
  AL · Large bank ($50B and above)

  We are also exposed to risks arising from the use of AI technologies by bad actors to commit fraud and misappropriate funds and to facilitate cyber-attacks and other similar incidents.

  Sees AI as a riskRead it in the report
• Renasant Corp
  MS · Mid-size bank ($1B to $50B)

  The Company’s development and use of artificial intelligence, including generative and agentic artificial intelligence and machine learning, presents risks and challenges that may materially and adversely impact the Company’s business.

  Sees AI as a riskRead it in the report
• Republic Bancorp Inc
  KY · Mid-size bank ($1B to $50B)

  AI, particularly generative AI, adoption risks including performance failures, bias, or reliance on third-party AI vendors, and more effective adoption by industry competitors;

  Sees AI as a riskRead it in the report
• S&T Bancorp
  PA · Mid-size bank ($1B to $50B)

  the rapid evolution of artificial intelligence, generative artificial intelligence and quantum computing has enabled malicious actors to develop more advanced social engineering attacks.

  Sees AI as a riskRead it in the report
• Santander Holdings USA, Inc.
  MA · Large bank ($50B and above)

  Advances in AI, including generative AI, may also be used by threat actors to facilitate cyber attacks, including the creation of highly convincing phishing and social-engineering campaigns, automated malware development, deepfake-enabled fraud

  Sees AI as a riskRead it in the report
• SouthState Bank Corp
  FL · Large bank ($50B and above)

  We have implemented an AI governance function and risk management framework that includes a risk assessment of internal and vendor AI solutions, due diligence, model validation, and controls.

  Sees AI as a riskRead it in the report
• State Street Corp
  MA · Large bank ($50B and above)

  We also use artificial intelligence, generative artificial intelligence and machine learning models to automate or enhance certain business processes.

  Sees AI as a riskRead it in the report
• Stock Yards Bancorp, Inc.
  KY · Mid-size bank ($1B to $50B)

  The development and use of generative artificial intelligence (AI) technology presents risks and challenges that may adversely impact our business, financial condition and results of operations.

  Sees AI as a riskRead it in the report
• Synchrony Financial
  CT · Large bank ($50B and above)

  risks related to the use of generative AI. Our information security team, led by our Chief Information Security Officer ("CISO"), in collaboration with our Risk Committee and our executive leadership team, closely monitors our information security program

  Explains how AI is controlledRead it in the report
• Trico Bancshares /
  CA · Mid-size bank ($1B to $50B)

  The increased use and capacity of AI, Generative AI, large language models (LLMs), and AI agents by customers, vendors and competitors increases risks to our business.

  Sees AI as a riskRead it in the report
• Truist Financial Corp
  NC · Large bank ($50B and above)

  the increasing use of machine learning and generative AI, and there can be no assurance that future cybersecurity incidents, including incidents experienced by third parties, will not have a material adverse impact on Truist

  Sees AI as a riskRead it in the report
• Unity Bancorp Inc
  NJ · Mid-size bank ($1B to $50B)

  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.

  Using AI nowRead it in the report
• Valley National Bancorp
  NY · Large bank ($50B and above)

  We have made, and expect to continue to make investments to integrate artificial intelligence tools into our solutions, including generative artificial intelligence, machine learning, agentic artificial intelligence and similar tools and technologies

  Sees AI as a riskRead it in the report
• WSFS Financial Corp
  DE · Mid-size bank ($1B to $50B)

  The use of AI applications, including large language models, has resulted in, and may in the future result in, cybersecurity vulnerabilities or incidents that implicate the personal information, intellectual property, proprietary data or other sensitive information

  Sees AI as a riskRead it in the report
• Webster Financial Corp
  CT · Large bank ($50B and above)

  AI models, including generative AI models, may produce output or influence us or third-party service providers to take actions that are incorrect, that result in the release of private, confidential, or proprietary information

  Sees AI as a riskRead it in the report
• Wintrust Financial Corp
  IL · Large bank ($50B and above)

  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.

  Sees AI as a riskRead it in the report
• Zions Bancorporation, National Association
  UT · Large bank ($50B and above)

  Emerging technologies—including generative AI, mobile platforms, quantum computing, and cloud computing—continue to heighten operational and cybersecurity risks.

  Sees AI as a riskRead it in the report
• Alerus Financial Corp
  ND · Mid-size bank ($1B to $50B)

  Artificial intelligence algorithms may be flawed, for example datasets may contain biased information or otherwise be insufficient, and inappropriate or controversial data practices could impair the acceptance of artificial intelligence solutions and result in burdensome new regulations.

  Sees AI as a riskRead it in the report
• Ameriserv Financial Inc
  PA · Mid-size bank ($1B to $50B)

  Emerging technologies, such as artificial intelligence (including machine learning, generative artificial intelligence and agentic artificial intelligence tools) and quantum computing, have the potential to intensify competition and accelerate disruption in the financial services industry.

  Sees AI as a riskRead it in the report
• Ames National Corp
  IA · Mid-size bank ($1B to $50B)

  The development and use of AI presents potential risks and challenges to our business and may require significant additional investments in infrastructure, personnel and training.

  Sees AI as a riskRead it in the report
• Bank First Corp
  WI · Mid-size bank ($1B to $50B)

  The development and use of AI presents a number of risks and challenges to the Company’s business. The legal and regulatory environment relating to AI is uncertain and rapidly evolving, both in the U.S. and internationally

  Sees AI as a riskRead it in the report
• Banner Corp
  WA · Mid-size bank ($1B to $50B)

  Operational risks also arise from potential system failures, over-reliance on AI, and integration challenges with existing infrastructure. Disruptions in AI systems could impact critical functions such as fraud detection, transaction monitoring, and client support.

  Sees AI as a riskRead it in the report
• Bar Harbor Bankshares
  ME · Mid-size bank ($1B to $50B)

  emerging technologies, such as artificial intelligence (including machine learning and generative artificial intelligence) and quantum computing, which may be used to enhance the tactics, techniques and procedures described above and facilitate new cyber threats

  Sees AI as a riskRead it in the report
• Blue Ridge Bankshares, Inc.
  VA · Mid-size bank ($1B to $50B)

  The development and use of AI presents a number of risks and challenges to the Company’s business. The legal and regulatory environment relating to AI is uncertain and rapidly evolving, both in the U.S. and internationally

  Sees AI as a riskRead it in the report
• Bridgewater Bancshares Inc
  MN · Mid-size bank ($1B to $50B)

  Artificial intelligence algorithms may be flawed, for example datasets may contain biased information or otherwise be

  Sees AI as a riskRead it in the report
• Burke & Herbert Financial Services Corp.
  VA · Mid-size bank ($1B to $50B)

  The use of artificial intelligence models developed by third parties introduces risks related to how those models are developed, trained, and deployed, including unauthorized material in training data and limited visibility into risk mitigation steps.

  Sees AI as a riskRead it in the report
• California BanCorp
  CA · Mid-size bank ($1B to $50B)

  The use of artificial intelligence in our marketplace may result in reputational harm or liability, or could otherwise adversely affect our business.

  Sees AI as a riskRead it in the report
• Carter Bankshares, Inc.
  VA · Mid-size bank ($1B to $50B)

  AI models, particularly generative AI tools, may produce inaccurate, incomplete, or misleading outputs; reflect biases presented in training data; improperly disclose confidential, proprietary, or personal information; or infringe upon the intellectual property rights of others.

  Sees AI as a riskRead it in the report
• Central Pacific Financial Corp
  HI · Mid-size bank ($1B to $50B)

  The techniques used in cyberattacks change rapidly and are increasingly sophisticated, including the use of generative artificial intelligence and deepfakes, and potential future use of quantum computing, and as a result, cyberattacks or data security breaches may be more difficult to anticipate.

  Sees AI as a riskRead it in the report
• Citizens & Northern Corp
  PA · Mid-size bank ($1B to $50B)

  The development and use of AI presents a number of risks and challenges to the Corporation's business. The legal and regulatory environment relating to AI is uncertain and rapidly evolving, both in the U.S. and internationally

  Sees AI as a riskRead it in the report
• Colony Bankcorp Inc
  GA · Mid-size bank ($1B to $50B)

  AI models, particularly generative AI models, may produce output or take action that is incorrect, that reflects biases included in the data on which they are trained, that results in the release of private, confidential, or proprietary information

  Sees AI as a riskRead it in the report
• Columbia Banking System, Inc.
  WA · Large bank ($50B and above)

  The 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, both in the U.S. and internationally

  Sees AI as a riskRead it in the report
• Community West Bancshares
  CA · Mid-size bank ($1B to $50B)

  The 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, both in the U.S. and internationally

  Sees AI as a riskRead it in the report
• Equity Bancshares Inc
  KS · Mid-size bank ($1B to $50B)

  The development and use of AI presents a number of risks and challenges to the Company’s business. The legal and regulatory environment relating to AI is uncertain and rapidly evolving, both in the U.S. and internationally

  Sees AI as a riskRead it in the report
• FVCBankcorp, Inc.
  VA · Mid-size bank ($1B to $50B)

  The 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 regulatory schemes targeted specifically at AI

  Sees AI as a riskRead it in the report
• Farmers & Merchants Bancorp
  CA · Mid-size bank ($1B to $50B)

  Emerging technologies, such as artificial intelligence (including machine learning and generative artificial intelligence) and quantum computing, have the potential to intensify competition and accelerate disruption in the financial services industry.

  Sees AI as a riskRead it in the report
• Fidelity D & D Bancorp Inc
  PA · Mid-size bank ($1B to $50B)

  Its customers and potential customers may express adverse opinions concerning its use of AI and machine learning that could result in brand or reputational harm, competitive harm, or legal liability.

  Sees AI as a riskRead it in the report
• First Community Corp
  SC · Mid-size bank ($1B to $50B)

  The development and use of AI by us or our third-party vendors poses significant risks. The evolving legal and regulatory landscape—covering intellectual property, privacy, consumer protection, employment, and more—could force costly changes and heighten non-compliance risks.

  Sees AI as a riskRead it in the report
• First Financial Bancorp
  OH · Mid-size bank ($1B to $50B)

  Increased use of artificial intelligence (AI) by vendors can further increase the risks of a cybersecurity breach, as discussed in the Risk Factor titled “The increased use and capacity of AI, Generative AI, large language models (LLMs), and AI agents by customers, vendors and competitors increases

  Sees AI as a riskRead it in the report
• First Keystone Corp
  PA · Mid-size bank ($1B to $50B)

  The Corporation's customers and potential customers may express adverse opinions concerning its use of AI and machine learning that could result in brand or reputational harm, competitive harm, or legal liability.

  Sees AI as a riskRead it in the report
• First Us Bancshares, Inc.
  AL · Mid-size bank ($1B to $50B)

  We are also exposed to risks arising from the use of AI technologies by bad actors to commit fraud and misappropriate funds and to facilitate cyberattacks. Generative AI, if used to perpetrate fraud or launch cyberattacks, could create panic at a particular financial institution

  Sees AI as a riskRead it in the report
• First Western Financial Inc
  CO · Mid-size bank ($1B to $50B)

  The development and use of AI presents a number of risks and challenges to the Company’s business. The legal and regulatory environment relating to AI is uncertain and rapidly evolving, both in the U.S. and internationally

  Sees AI as a riskRead it in the report
• Firstsun Capital Bancorp
  CO · Mid-size bank ($1B to $50B)

  the increased sophistication and activities of organized crime, hackers, terrorists, activists, and other external parties, any of which may see their effectiveness increase as a result of artificial intelligence (“AI”), including the use of generative AI to conduct more sophisticated social

  Sees AI as a riskRead it in the report
• Franklin Financial Services Corp
  PA · Mid-size bank ($1B to $50B)

  The Corporation's customers and potential customers may express adverse opinions concerning its use of AI and machine learning that could result in brand or reputational harm, competitive harm, or legal liability.

  Sees AI as a riskRead it in the report
• GBank Financial Holdings Inc.
  NV · Mid-size bank ($1B to $50B)

  The legal and regulatory environment relating to AI is uncertain and rapidly evolving, both in the United States and internationally, and includes regulatory schemes targeted specifically at AI as well as provisions in intellectual property, privacy, consumer protection, employment, and other laws

  Sees AI as a riskRead it in the report
• HBT Financial, Inc.
  IL · Mid-size bank ($1B to $50B)

  emerging trends, such as generative artificial intelligence, have the potential to disrupt the banking industry. Although generative artificial intelligence offers opportunities to enhance operational efficiency, it also introduces risks, including fraud, security vulnerabilities, and compliance

  Sees AI as a riskRead it in the report
• Hawthorn Bancshares, Inc.
  MO · Mid-size bank ($1B to $50B)

  The development and use of AI presents risks and challenges to the Company’s business. The legal and regulatory environment relating to AI is uncertain and rapidly evolving, both in the U.S. and internationally

  Sees AI as a riskRead it in the report
• Hilltop Holdings Inc.
  TX · Mid-size bank ($1B to $50B)

  any implementation by us of certain new technologies, such as artificial intelligence, machine learning and other large language models and similar technologies, can expose us to new or increased operational risks, including risks related to our system of internal controls

  Sees AI as a riskRead it in the report
• Home Bancshares Inc
  AR · Mid-size bank ($1B to $50B)

  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.

  Sees AI as a riskRead it in the report
• Hope Bancorp Inc
  CA · Mid-size bank ($1B to $50B)

  The development and use of artificial intelligence (“AI”) presents risks and challenges that may adversely impact the Company’s business.

  Sees AI as a riskRead it in the report
• Independent Bank Corp
  MA · Mid-size bank ($1B to $50B)

  The financial services industries continually experience rapid technological change with frequent introductions of new technology-driven products and services, such as AI, including generative AI, machine learning, and similar tools and technologies

  Sees AI as a riskRead it in the report
• John Marshall Bancorp, Inc.
  VA · Mid-size bank ($1B to $50B)

  The development and use of AI presents a number of risks and challenges to the Company’s business. The legal and regulatory environment relating to AI is uncertain and rapidly evolving

  Sees AI as a riskRead it in the report
• Landmark Bancorp Inc
  KS · Mid-size bank ($1B to $50B)

  Artificial intelligence algorithms may be flawed, for example datasets may contain biased information or otherwise be insufficient, and inappropriate or controversial data practices could impair the acceptance of artificial intelligence solutions and result in burdensome new regulations.

  Sees AI as a riskRead it in the report
• M&T Bank Corp
  NY · Large bank ($50B and above)

  AI models, including generative AI models may produce output or influence the Company or its third-party service providers to take actions that are incorrect, that result in the release of private, confidential or proprietary information

  Sees AI as a riskRead it in the report
• Merchants Bancorp
  IN · Mid-size bank ($1B to $50B)

  AI use cases have varied widely and include customer chatbots, fraud detection, and credit scoring. Generative AI in particular has garnered significant attention recently, following the commercial availability of large language model tools

  Sees AI as a riskRead it in the report
• MetroCity Bankshares, Inc.
  GA · Mid-size bank ($1B to $50B)

  AI models, particularly generative AI models, may produce output or take action that is incorrect, that reflects biases included in the data on which they are trained, that results in the release of private, confidential, or proprietary information

  Sees AI as a riskRead it in the report
• National Bankshares Inc
  VA · Mid-size bank ($1B to $50B)

  The 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

  Sees AI as a riskRead it in the report
• Northpointe Bancshares Inc
  MI · Mid-size bank ($1B to $50B)

  The development and use of AI presents a number of risks and challenges to the Company’s business. The legal and regulatory environment relating to AI is uncertain and rapidly evolving, both in the U.S. and internationally

  Sees AI as a riskRead it in the report
• Old Second Bancorp Inc
  IL · Mid-size bank ($1B to $50B)

  The development and use of AI present a number of risks and challenges to our business. The legal and regulatory environment relating to AI is uncertain and rapidly evolving, both in the U.S. and internationally

  Sees AI as a riskRead it in the report
• Orrstown Financial Services Inc
  PA · Mid-size bank ($1B to $50B)

  Emerging technologies, such as artificial intelligence (including machine learning and generative artificial intelligence) and quantum computing, have the potential to further intensify competition and accelerate disruption in the financial services industry.

  Sees AI as a riskRead it in the report
• PCB Bancorp
  CA · Mid-size bank ($1B to $50B)

  Artificial intelligence algorithms may be flawed, for example datasets may contain biased information or otherwise be insufficient; and inappropriate or controversial data practices could impair the acceptance of artificial intelligence solutions and result in burdensome new regulations.

  Sees AI as a riskRead it in the report
• Pathward Financial, Inc.
  SD · Mid-size bank ($1B to $50B)

  We are also exposed to the risk that generative AI models may produce incorrect outputs, release confidential information, reflect biases, infringe intellectual property, or otherwise cause harm.

  Sees AI as a riskRead it in the report
• Patriot National Bancorp Inc
  CT · Mid-size bank ($1B to $50B)

  AI models, particularly generative or agentic AI models, may produce outputs or take action that is incorrect, that reflects biases included in the data on which they are trained, that results in the release of private, confidential, or proprietary information

  Sees AI as a riskRead it in the report
• Peoples Financial Services Corp.
  PA · Mid-size bank ($1B to $50B)

  AI models, particularly generative AI models, may produce output or take action that is incorrect, that reflects biases included in the data on which they are trained, that results in the release of private, confidential, or proprietary information

  Sees AI as a riskRead it in the report
• Pinnacle Financial Partners, Inc.
  GA · Large bank ($50B and above)

  The rapid evolution and increased adoption of generative artificial intelligence is further increasing risks in this area, including by making fraud detection more difficult, particularly with detection devices that use voice recognition or authentication.

  Sees AI as a riskRead it in the report
• Primis Financial Corp.
  VA · Mid-size bank ($1B to $50B)

  The development and use of AI present a number of risks and challenges to our business. The legal and regulatory environment relating to AI is uncertain and rapidly evolving, both in the U.S. and internationally

  Sees AI as a riskRead it in the report
• QCR Holdings Inc
  IL · Mid-size bank ($1B to $50B)

  Artificial intelligence algorithms may be flawed, for example datasets may contain biased information or otherwise be insufficient; and inappropriate or controversial data practices could impair the acceptance of artificial intelligence solutions and result in burdensome new regulations.

  Sees AI as a riskRead it in the report
• Red River Bancshares Inc
  LA · Mid-size bank ($1B to $50B)

  The 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.

  Sees AI as a riskRead it in the report
• Seacoast Banking Corp of Florida
  FL · Mid-size bank ($1B to $50B)

  The legal and regulatory environment applicable to AI is uncertain, rapidly evolving, and includes both AI specific regulatory schemes and broader requirements under intellectual property, privacy, consumer protection, employment, and other laws.

  Sees AI as a riskRead it in the report
• Simmons First National Corp
  AR · Mid-size bank ($1B to $50B)

  The use of artificial intelligence models developed by third parties introduces risks related to how those models are developed, trained, and deployed, including unauthorized material in training data and limited visibility into risk mitigation steps.

  Sees AI as a riskRead it in the report
• Smartfinancial Inc.
  TN · Mid-size bank ($1B to $50B)

  The 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, both in the U.S. and internationally

  Sees AI as a riskRead it in the report
• Southern First Bancshares Inc
  SC · Mid-size bank ($1B to $50B)

  The development and use of AI by us or our third-party vendors poses significant risks. The evolving legal and regulatory landscape—covering intellectual property, privacy, consumer protection, employment, and more—could force costly changes and heighten non-compliance risks.

  Sees AI as a riskRead it in the report
• Southside Bancshares Inc
  TX · Mid-size bank ($1B to $50B)

  The development and use of AI presents a number of risks and challenges to the Company’s business. The legal and regulatory environment relating to AI is uncertain and rapidly evolving, both in the U.S. and internationally

  Sees AI as a riskRead it in the report
• Stellar Bancorp, Inc.
  TX · Mid-size bank ($1B to $50B)

  The development and use of AI presents a number of risks and challenges to the Company’s business. The legal and regulatory environment relating to AI is uncertain and rapidly evolving

  Sees AI as a riskRead it in the report
• Texas Capital Bancshares Inc
  TX · Mid-size bank ($1B to $50B)

  The development and use of AI presents risks and challenges that may adversely impact the Company’s business. The Company or its third-party (or fourth party) vendors, clients or counterparties may develop or incorporate AI technology in certain business processes, services, or products.

  Sees AI as a riskRead it in the report
• Tri-County Financial Group, Inc.
  IL · Mid-size bank ($1B to $50B)

  Artificial intelligence algorithms may be flawed, for example datasets may contain biased information or otherwise be insufficient, and inappropriate or controversial data practices could impair the acceptance of artificial intelligence solutions

  Sees AI as a riskRead it in the report
• TrustCo Bank Corp NY
  NY · Mid-size bank ($1B to $50B)

  We are also exposed to risks arising from the use of AI technologies by bad actors to commit fraud and misappropriate funds and to facilitate cyberattacks. Generative AI, if used to perpetrate fraud or launch cyberattacks, could create panic at a particular financial institution

  Sees AI as a riskRead it in the report
• United Community Banks Inc
  SC · Mid-size bank ($1B to $50B)

  The emergence and maturation of artificial intelligence capabilities has led to new and/or more sophisticated methods of attack, including fraud that relies upon “deep fake” impersonation technology, or other forms of generative automation that have scaled up the effectiveness of cyber threat

  Sees AI as a riskRead it in the report
• Virginia National Bankshares Corp
  VA · Mid-size bank ($1B to $50B)

  The development and use of AI presents a number of risks and challenges to the Company’s business. The legal and regulatory environment relating to AI is uncertain and rapidly evolving

  Sees AI as a riskRead it in the report
• Wafd Inc
  WA · Mid-size bank ($1B to $50B)

  AI models, particularly generative or agentic AI models, may produce outputs or take action that is incorrect, that

  Sees AI as a riskRead it in the report
• Washington Trust Bancorp Inc
  RI · Mid-size bank ($1B to $50B)

  Emerging technologies, such as artificial intelligence (including machine learning and generative artificial intelligence) and quantum computing, have the potential to further intensify competition and accelerate disruption in the financial services industry.

  Sees AI as a riskRead it in the report
• West Bancorporation Inc
  IA · Mid-size bank ($1B to $50B)

  Artificial intelligence algorithms may be flawed, for example datasets may contain biased information or otherwise be insufficient; and inappropriate or controversial data practices could impair the acceptance of artificial intelligence solutions and result in burdensome new regulations.

  Sees AI as a riskRead it in the report
• Western Alliance Bancorporation
  AZ · Large bank ($50B and above)

  AI models, particularly generative or agentic AI models, may produce outputs or take action that is incorrect, that reflects biases included in the data on which they are trained, that results in the release of private, confidential, or proprietary information

  Sees AI as a riskRead it in the report
• Wilson Bank Holding Co
  TN · Mid-size bank ($1B to $50B)

  The rapid evolution and increased adoption of generative artificial intelligence is further increasing risks in this area, including by making fraud detection more difficult, particularly with detection devices that use voice recognition or authentication.

  Sees AI as a riskRead it in the report