Engagements

Four ways to engage. The fourth one renews.

Entry is the diagnostic. Everything after it runs against an examination calendar the institution does not control.

01

ZERO™ Diagnostic

Four to eight weeks. The entry point, and the prerequisite for everything else.

  • Full inventory — vendor, shadow, agentic
  • Four-tier risk classification
  • Ownership map, named per system
  • Data Readiness Gate score
  • Maturity heatmap and 90-day roadmap
02

Fractional Governance Lead

An embedded senior governance executive. Six-month minimum.

  • Named senior governance executive
  • Risk and audit committee participation
  • Examiner-facing posture
  • Board reporting cadence
  • New-deployment oversight
03

Governance Build

Three to nine months. Diagnostic first.

  • Board-approved AI governance charter
  • Risk tiering standard and RACI
  • Validation framework, SR 11-7
  • Agentic control layer
  • Continuous monitoring system
04

ZERO™ Assurance

Annual. Renewed against the examination calendar, not a new decision.

  • Gate and five-stage re-score
  • Independent control validation
  • Vendor AI re-attestation
  • Evidence pack refreshed for examination
  • Board attestation letter

Engagements are scoped and priced against institution size, portfolio complexity and examination posture. Pricing is discussed in the working session.

The First Ninety Days

Ninety days from now, here is what you hold.

Not a strategy document. Nine artifacts an examiner can be walked through, and a roadmap with named owners against dated actions.
Weeks 1–2

Discovery

  • Enterprise AI register
  • Vendor-embedded sweep
  • Shadow AI surfacing
  • Data readiness gate scored
Weeks 3–5

Classification & ownership

  • Four-tier risk classification
  • Named owner per system
  • Agentic systems tiered separately
  • Accountability map
Weeks 6–8

Gap and posture

  • Gap assessment against L3
  • Monitoring posture, six dimensions
  • Maturity heatmap, all five stages
  • Detailed findings with evidence
Weeks 9–12

Board and roadmap

  • Board-ready executive deck
  • 90-day remediation roadmap
  • Owners against dated actions
  • Examination evidence pack
Common Questions

What institutions ask first

How long does the diagnostic take?Four to eight weeks · nine artifacts · 90-day roadmap
We already have an AI policy. Do we need this?A policy is not an inventory. One institution reported 14 systems; discovery found 41
Which regulations do you map to?SR 11-7 · OCC · NCUA · FFIEC · BCBS 239 · NIST AI RMF · ISO 42001 · EU AI Act
Do you cover agentic AI?Tiered separately by autonomy and blast radius, with decision authority mapped
What if our data is not ready?The gate sequences remediation. Blocked means sequenced, not declined

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.