ZERO™ Operating Model · USPTO Serial 99781150

You cannot govern what you have not found.

Most regulated institutions are operating three to five times more AI than they have on record. The exposure is not the AI. It is the inventory, the ownership, and the evidence.

3–5×
More vendor AI than institutions report
18%
Have governance for the AI they deployed
17%
Have board-level AI oversight
The Case

The institution reported 14 AI systems. Discovery found 41.

A regulated financial institution, mid-size, with a functioning model risk committee and a documented AI policy. Nothing about it was negligent. The governed inventory was simply the only inventory anyone had ever built.
Formally governed systems14
Vendor-embedded copilots11 · not on the register
Unregistered analytics workflows9 · not on the register
GenAI productivity tools4 · not on the register
Shadow underwriting automations3 · not on the register
Total AI systems in operation41

24 of 41 systems had no defensible inventory, classification, or owner of record. The first question is not how well you govern AI. It is whether you know how much of it you have.

The Operating Model

Frameworks describe. Platforms instrument. ZERO™ operates.

Five stages, one precondition gate, and a loop that closes — monitoring routes change back into the model rather than ending it.
D

Discover

Vendor, shadow and agentic AI swept into one register.

C

Classify

Four-tier risk by consequence, not complexity.

A

Assign

A named human per system. Not a team.

G

Govern

Controls, validation, and the artifact pack.

M

Monitor

Signals routed back into the model on change.

How ZERO™ works →

Track Record

Built inside institutions that get examined

Bank of America
Morgan Stanley
Citigroup
RBC Capital Markets
Hudson Valley Credit Union
Deloitte
Accenture

Institutions where our founder held leadership roles or delivered engagements. Professional history — not client relationships of AI Advantages LLC.

420+
AI systems deployed at scale
Zero
Regulatory findings
25+
Years in regulated finance
2
ISO Lead Auditor certifications
Services

Four ways to engage

Entry is the diagnostic. Everything after it runs on a calendar the institution does not set.
01

ZERO™ Diagnostic

Four to eight weeks. Full inventory, risk classification, ownership map, data gate score, maturity heatmap and a 90-day roadmap.

02

Fractional Governance Lead

An embedded senior governance executive — risk and audit committee participation, examiner-facing posture, board reporting cadence.

03

Governance Build

Board-approved charter, risk tiering standard and RACI, SR 11-7 validation framework, agentic control layer, continuous monitoring.

04

ZERO™ Assurance

Annual re-score, independent control validation, vendor AI re-attestation, examiner evidence pack refreshed, board attestation letter.

See the full engagement model →

Zero findings is not luck.
It's architecture.
Rehan Kausar · Chief AI Officer
Insights

The Zero Findings Brief

AI governance, operating models, and what actually holds up under examination.

The Shadow AI Advantage

Why governance accelerates ROI rather than slowing it — and what federal agencies found when they went and counted.

CIO TechWorld

Who approved the AI to approve?

Decision authority in agentic systems, and the accountability gap that opens when an agent acts without a mapped human owner.

Zero Findings Brief

Governance is a calendar

Examination cycles, vendor change notifications and model drift set the rhythm. The institution does not choose when the examiner arrives.

Zero Findings Brief

Read the insights →

Your AI governance program may look great on paper. Will it survive a regulatory examination?

Sixty minutes. No cost. You leave with a one-page Exposure Hypothesis.