When a Bank Does Not Build the AI: Governing Third-Party Models and Agents
Artificial intelligence is becoming embedded in banking technology, but banks are not developing or directly operating all of it. Financial institutions increasingly rely on providers whose platforms incorporate predictive models, generative AI, large language models, and agentic capabilities into lending, fraud detection, customer interactions, document processing, and other business processes.These technologies do not present identical risks. A predictive model that produces a fraud score behaves differently from an LLM that summarizes a case or an AI agent that can retrieve information, invoke tools, and initiate actions. The governing question is therefore not simply whether a product “uses AI.” Banks need to understand what the technology can access, what it can produce or i...