- Essays··8 min read
Two Regulators Blinked. The Agent Fleet Did Not.
Two regulators blinked on the AI question in a single five-month window. The largest banks did not stop deploying. The gap between those two facts is the most important live risk in financial services right now.
model-risk-managementagentic-aibank-supervisioneu-ai-actRead - 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