- Essays··9 min read
The model-risk carve-out: why US banks got a temporary reprieve from agentic AI oversight while EU lenders face their deadline
SR 26-2, the Federal Reserve's updated model-risk guidance, carves generative and agentic AI out of supervisory scope — not as relief, but as a placeholder while regulators decide what replaces SR 11-7. The EU AI Act's high-risk obligations arrive on 2 August. For multinational banks, the result is a structural supervision paradox: US headquarters has time but no clarity; European subsidiaries have clarity but no time.
model-riskagentic-aieu-ai-actbanking-regulationRead - Essays··7 min read
The Agentic AI Gap: SR 11-7 Is Dead, the EU AI Act Is Late, and Banks Are Shipping Agents Anyway
Three jurisdictions, zero frameworks designed for the agents already in production. The governance gap between SR 26-2's carve-out, the EU's sixteen-month delay, and the UK's 'further work' is where the first enforcement action will land.
agentic-aimodel-risk-managementeu-ai-actbanking-regulationRead