# Bread Financial Holdings: AI strategy

Source: https://www.bankingnewsai.com/banks/bread-financial
Last updated: Oct 5, 2026

*A private-label and co-brand card issuer that treats AI as operational-excellence spend: 200-plus machine-learning models, an in-house agentic platform under its CTO, 'fast follower' discipline and a governance-first, ROI-tracked rollout.*

## How is Bread Financial using AI?

Bread Financial Holdings, the Columbus, Ohio card issuer behind Comenity Capital Bank (a Utah industrial bank with about $13.9 billion in assets at June 30, 2026) and Comenity Bank, has one of the more concrete AI records among mid-sized US card lenders. On its fourth-quarter 2025 call, Chief Financial Officer Perry Beberman said the company has 'over 200 machine learning models embedded in our business'. Its 2025 10-K says it has built an AI-powered knowledge-management tool for customer-care associates and is evaluating deep learning and AI tools for credit risk. In April 2026 Chief Technology Officer Allegra Driscoll said Bread is developing its own agentic AI platform and works with vendors including Harvey and Jasper. CEO Ralph Andretta told investors in September 2025 that Bread is a 'fast follower' that starts from use cases, such as using AI to review every customer call instead of a 2% to 3% sample, and on the July 2026 call said Bread is collaborating with partners on agentic-commerce and servicing use cases. Management says AI spending is governed and tracked for return, and it guided to higher expenses in the second half of 2026 partly for AI capabilities.

## At a glance

| Field | Value |
| --- | --- |
| Lead bank | Comenity Capital Bank |
| Ticker | BFH |
| Headquarters | Columbus, OH |
| Consolidated assets | $13,859 million (Jun 30, 2026) |
| Federal Reserve rank | 120 |
| Charter | Utah-chartered industrial bank (FDIC primary federal regulator; Utah Department of Financial Institutions). Bread Financial also owns Comenity Bank (Delaware; Fed rank 185, $7,371 million at June 30, 2026), so the holding company's card business sits in two insured banks. |

## Flagship platform: In-house agentic AI platform and AI knowledge-management tool

Chief Technology Officer Allegra Driscoll told Fortune in April 2026 that Bread Financial is developing its own agentic AI platform, and that it could replace vendor tools such as legal-AI firm Harvey and content platform Jasper as that platform matures. The 2025 10-K separately says Bread has developed an AI-powered knowledge-management solution for its customer-care associates. ([Fortune](https://fortune.com/2026/04/08/amid-the-saaspocalypse-cios-and-ctos-take-a-harder-line-with-their-vendors), [Bread Financial Holdings (SEC filing)](https://www.sec.gov/Archives/edgar/data/1101215/000110121526000016/bfh-20251231.htm))

## Key points

- Scale of existing ML: CFO Perry Beberman said on the Q4 2025 call that Bread has over 200 machine learning models embedded in its business (call of 2026-01-29).
- Customer service: the 10-K describes an AI-powered knowledge-management solution for customer-care associates, and CEO Ralph Andretta said in September 2025 that AI lets Bread review all customer calls for complaint trends rather than a 2% to 3% sample.
- Agentic commerce is both a use case and a risk: Bread is working with brand partners on agentic-commerce and servicing use cases (Q2 2026 call), while the 10-K flags agentic commerce as a competitive and regulatory risk.
- Governance first: management says it set AI governance for partner and customer data before choosing use cases, runs a lab to test tools, and tracks AI investments against a return framework (Bank of America conference, February 2026; Q1 2026 call).
- Vendors and build: Bread uses outside AI products such as Harvey and Jasper but says its own agentic platform could displace some of them; Driscoll limits AI vendor contracts to one year.
- Spend: 2026 guidance includes positive operating leverage while 'investing in AI capabilities'; the CFO said expenses would rise sequentially in the third and fourth quarters, partly for AI technology.
- Charter detail: Comenity Capital Bank (Fed rank 120) is a Utah industrial bank outside the Bank Holding Company Act; Bread's own supervisors are the FDIC and Utah regulators, plus the CFPB for consumer credit.

## Timeline

- Jul 23, 2026 — **Q2 2026 call: agentic commerce and servicing use cases with partners** Andretta said Bread is integrating AI for productivity, innovation and risk management and collaborating with partners on agentic-commerce and servicing use cases; the CFO said third- and fourth-quarter expenses would rise partly for AI technology, with an opportunity to lean in as agentic opportunities emerge. The 10-Q filed July 28 repeats that Bread continues to invest in AI capabilities. ([Investing.com](https://investing.com/news/transcripts/earnings-call-transcript-bread-financial-tops-q2-2026-estimates-on-strong-credit-sales-93CH-4809145), [Bread Financial Holdings (SEC filing)](https://www.sec.gov/Archives/edgar/data/1101215/000110121526000074/bfh-20260630.htm))
- Apr 23, 2026 — **Q1 2026 call: AI deployed 'responsibly across the enterprise'** Management said AI investments aim at productivity, innovation and risk management and are reinforced by a value-tracking framework to ensure return on investment. ([Investing.com](https://investing.com/news/transcripts/earnings-call-transcript-bread-financial-q1-2026-beats-expectations-with-strong-growth-93CH-4632777))
- Apr 8, 2026 — **CTO: own agentic AI platform, one-year vendor contracts** Fortune reported Driscoll keeps generative-AI vendor agreements to one year, sometimes pays two vendors to compare them, and could replace vendors such as Harvey and Jasper as Bread develops its own agentic AI platform. ([Fortune](https://fortune.com/2026/04/08/amid-the-saaspocalypse-cios-and-ctos-take-a-harder-line-with-their-vendors))
- Feb 13, 2026 — **10-K: AI knowledge tool, AI risk factor, agentic commerce** The 2025 10-K cites an AI-powered knowledge-management solution for care associates, possible use of deep learning and AI tools in credit risk, a Pluralsight-based AI-in-data-science training cohort, and a risk factor on AI regulation, model risk, deepfakes and agentic commerce. ([Bread Financial Holdings (SEC filing)](https://www.sec.gov/Archives/edgar/data/1101215/000110121526000016/bfh-20251231.htm))
- Feb 10, 2026 — **Bank of America conference: governance before use cases** Management said it first set AI governance to protect partner and customer data, then picked problems AI can solve, set up an AI lab, and measures return on AI investment; AI is expected to help service, underwriting and fraud prevention. ([Investing.com](https://investing.com/news/transcripts/bread-financial-at-bank-of-america-conference-strategic-growth-and-innovation-93CH-4498295))
- Jan 29, 2026 — **Q4 2025 call: over 200 machine learning models** Beberman said Bread has over 200 machine learning models embedded in its business; the company also described accelerating AI adoption within its multi-year technology transformation and operational-excellence programme. ([Investing.com](https://investing.com/news/transcripts/earnings-call-transcript-bread-financial-q4-2025-beats-eps-expectations-93CH-4481011))
- Sep 9, 2025 — **CEO describes a 'fast follower' AI approach** At the Barclays financial services conference Andretta said Bread starts from use cases rather than technology, and that AI now lets it listen to all customer calls and extract trends instead of sampling 2% to 3%. ([Investing.com](https://investing.com/news/transcripts/bread-financial-at-barclays-conference-strategic-moves-and-market-insights-93CH-4231903))
- Jan 25, 2024 — **Allegra Driscoll named CTO; AI experiments for enterprise users** Bread appointed Driscoll, formerly a unit chief information officer at American Express, as Executive Vice President and Chief Technology Officer. American Banker reported the company was experimenting with AI to help enterprise users dig into data such as card activation rates. ([American Banker](https://americanbanker.com/payments/news/bread-cuts-expenses-as-charge-offs-rise-sharply))

## Where AI runs

| Use case | What | Status | Detail | Sources |
| --- | --- | --- | --- | --- |
| [Customer-facing chatbots](https://www.bankingnewsai.com/ai-regulation/by-use-case#customer-chatbots) | AI knowledge management for care associates | In production | An AI-powered knowledge-management solution built for customer-care associates, described in the 10-K as a way to reach the highest service standards. | [Bread Financial Holdings (SEC filing)](https://www.sec.gov/Archives/edgar/data/1101215/000110121526000016/bfh-20251231.htm) |
| [AI governance (general)](https://www.bankingnewsai.com/ai-regulation/by-use-case#governance-general) | AI review of all customer calls | In production | Andretta said AI lets Bread review all customer calls for complaint trends, which it can show regulators, and feed those trends into rep training. | [Investing.com](https://investing.com/news/transcripts/bread-financial-at-barclays-conference-strategic-moves-and-market-insights-93CH-4231903) |
| [Credit scoring & underwriting](https://www.bankingnewsai.com/ai-regulation/by-use-case#credit-underwriting) | Machine-learning credit models and possible deep learning | In production | Over 200 machine learning models are embedded in the business; the 10-K says Bread is evaluating the potential use of deep learning and AI tools in credit risk management. | [Investing.com](https://investing.com/news/transcripts/earnings-call-transcript-bread-financial-q4-2025-beats-eps-expectations-93CH-4481011), [Bread Financial Holdings (SEC filing)](https://www.sec.gov/Archives/edgar/data/1101215/000110121526000016/bfh-20251231.htm) |
| [Generative & agentic AI](https://www.bankingnewsai.com/ai-regulation/by-use-case#generative-agentic-ai) | Agentic commerce and servicing with brand partners | Pilot | Bread is collaborating with partners to develop agentic-commerce and servicing use cases, and is building an in-house agentic AI platform. | [Investing.com](https://investing.com/news/transcripts/earnings-call-transcript-bread-financial-tops-q2-2026-estimates-on-strong-credit-sales-93CH-4809145), [Fortune](https://fortune.com/2026/04/08/amid-the-saaspocalypse-cios-and-ctos-take-a-harder-line-with-their-vendors) |
| [Third-party & vendor AI](https://www.bankingnewsai.com/ai-regulation/by-use-case#third-party-vendors) | Short-term generative-AI vendor contracts | In production | Driscoll limits generative-AI vendor agreements to one year and probes vendor architecture; Bread works with Harvey (legal AI) and Jasper (content). | [Fortune](https://fortune.com/2026/04/08/amid-the-saaspocalypse-cios-and-ctos-take-a-harder-line-with-their-vendors) |
| [Fraud detection](https://www.bankingnewsai.com/ai-regulation/by-use-case#fraud) | AI-enabled fraud and cyber threats | In production | The 10-K says generative AI, including synthetic voice, adds identity-fraud risk and that threat actors use AI against security controls; fraud-related operational losses were $65 million in both 2025 and 2024. | [Bread Financial Holdings (SEC filing)](https://www.sec.gov/Archives/edgar/data/1101215/000110121526000016/bfh-20251231.htm) |

## Disclosed numbers

| Measure | Value | As of | Sources |
| --- | --- | --- | --- |
| Lead-bank assets, Comenity Capital Bank (Fed release) | $13,859 million | Jun 30, 2026 | [Federal Reserve Board](https://www.federalreserve.gov/releases/lbr/current/) |
| Comenity Bank assets (Fed release) | $7,371 million (rank 185) | Jun 30, 2026 | [Federal Reserve Board](https://www.federalreserve.gov/releases/lbr/current/) |
| Machine learning models embedded in the business | Over 200 | Jan 29, 2026 | [Investing.com](https://investing.com/news/transcripts/earnings-call-transcript-bread-financial-q4-2025-beats-eps-expectations-93CH-4481011) |
| Customer calls reviewed with AI | 100% of calls, versus a sample of 2% to 3% before | Sep 9, 2025 | [Investing.com](https://investing.com/news/transcripts/bread-financial-at-barclays-conference-strategic-moves-and-market-insights-93CH-4231903) |
| Fraud-related operational losses | $65 million in each of 2025 and 2024 | Dec 31, 2025 | [Bread Financial Holdings (SEC filing)](https://www.sec.gov/Archives/edgar/data/1101215/000110121526000016/bfh-20251231.htm) |
| Credit sales growth, Q2 2026 | 11% year over year | Jun 30, 2026 | [Investing.com](https://investing.com/news/transcripts/earnings-call-transcript-bread-financial-tops-q2-2026-estimates-on-strong-credit-sales-93CH-4809145) |

## Quotes

> "Our approach has been to be a fast follower, not to be on the cutting edge, but to be a fast follower because we want to invest thoughtfully and wisely." — Ralph Andretta, President and Chief Executive Officer, Sep 9, 2025 ([Investing.com](https://investing.com/news/transcripts/bread-financial-at-barclays-conference-strategic-moves-and-market-insights-93CH-4231903))

> "We have over 200 machine learning models embedded in our business." — Perry Beberman, Executive Vice President and Chief Financial Officer, Jan 29, 2026 ([Investing.com](https://investing.com/news/transcripts/earnings-call-transcript-bread-financial-q4-2025-beats-eps-expectations-93CH-4481011))

> "The conversations are going a lot deeper into the architecture of the third-party solutions, where in the past, I've been more focused on the capacity, security, and data privacy." — Allegra Driscoll, Chief Technology Officer, Apr 8, 2026 ([Fortune](https://fortune.com/2026/04/08/amid-the-saaspocalypse-cios-and-ctos-take-a-harder-line-with-their-vendors))

> "We are strategically integrating AI in ways that advance operational excellence by improving productivity and efficiency, enabling innovation, and enhancing risk management." — Ralph Andretta, President and Chief Executive Officer, Jul 23, 2026 ([Investing.com](https://investing.com/news/transcripts/earnings-call-transcript-bread-financial-tops-q2-2026-estimates-on-strong-credit-sales-93CH-4809145))

## Who runs AI

- **Ralph Andretta** — President and Chief Executive Officer ([Investing.com](https://investing.com/news/transcripts/earnings-call-transcript-bread-financial-tops-q2-2026-estimates-on-strong-credit-sales-93CH-4809145))
- **Allegra Driscoll** — Executive Vice President and Chief Technology Officer (appointed January 2024) ([American Banker](https://americanbanker.com/payments/news/bread-cuts-expenses-as-charge-offs-rise-sharply), [Fortune](https://fortune.com/2026/04/08/amid-the-saaspocalypse-cios-and-ctos-take-a-harder-line-with-their-vendors))
- **Perry Beberman** — Executive Vice President and Chief Financial Officer ([Investing.com](https://investing.com/news/transcripts/earnings-call-transcript-bread-financial-q4-2025-beats-eps-expectations-93CH-4481011))

## Regulators it answers to

- [FDIC](https://www.bankingnewsai.com/ai-regulation/fdic) — Comenity Capital Bank is a Utah industrial bank and the FDIC is its primary federal regulator (with the Utah Department of Financial Institutions); Comenity Bank is also FDIC-supervised, so third-party and model-risk expectations for AI sit with the FDIC. See [FDIC FIL-15-2026](https://www.bankingnewsai.com/ai-regulation/documents/fdic-fil-15-2026), [FDIC FIL-29-2023](https://www.bankingnewsai.com/ai-regulation/documents/fdic-fil-29-2023).
- [CFPB](https://www.bankingnewsai.com/ai-regulation/cfpb) — Credit cards and Bread Pay installment loans carry adverse-action and UDAAP duties; the CFPB's circulars on complex algorithms and chatbots apply to AI-assisted underwriting and servicing, and the 10-K lists the CFPB among its regulators. See [CFPB Circular 2022-03](https://www.bankingnewsai.com/ai-regulation/documents/cfpb-circular-2022-03), [CFPB Chatbots in Consumer Finance (issue spotlight, 2023)](https://www.bankingnewsai.com/ai-regulation/documents/cfpb-chatbots-in-consumer-finance-2023).
- [SEC](https://www.bankingnewsai.com/ai-regulation/sec) — Bread Financial Holdings is an NYSE-listed registrant, so its AI statements in the 10-K, 10-Q and on earnings calls are subject to SEC disclosure and AI-washing enforcement priorities. See [Division of Examinations FY2026 Priorities](https://www.bankingnewsai.com/ai-regulation/documents/sec-exam-priorities-fy2026).

## What the record suggests

### A card issuer's AI payoff is in servicing and risk

The concrete examples management gives, such as reviewing every customer call and 200-plus models, sit in servicing, collections-style analytics and credit, where a card lender has high volumes of repeatable decisions.

### Agentic commerce is a defensive and offensive bet

The 10-K treats autonomous AI shopping agents as a competitive and legal risk to branded cards, while management says partners are asking about agentic commerce; collaborating with partners on use cases is how Bread tries to keep its card the default in the purchase path.

### Build-versus-buy is being decided in public

Driscoll's one-year contracts and plan to build an agentic platform that could displace tools such as Harvey and Jasper suggest Bread expects vendor AI capabilities to churn and wants the orchestration layer in house.

### Expense guidance is the clearest budget signal

No AI budget is disclosed, but guidance for rising second-half 2026 expenses cites AI technology capabilities alongside growth costs, while management still promises positive operating leverage for 2026.

## FAQ

### Does Bread Financial use AI?

Yes. Bread says it has over 200 machine learning models in its business, uses AI to review all customer calls, has built an AI-powered knowledge tool for care associates, and is developing an in-house agentic AI platform. It has not published an AI budget or headline savings figure.

### Which bank is Bread Financial's lead bank?

Comenity Capital Bank, a Utah-chartered industrial bank supervised by the FDIC and the Utah Department of Financial Institutions, with about $13.9 billion in assets at June 30, 2026 (Fed rank 120). Bread also owns Comenity Bank in Delaware, with about $7.4 billion.

### Who runs AI at Bread Financial?

Technology and AI sit under Chief Technology Officer Allegra Driscoll, who joined in January 2024 and describes the in-house agentic platform and vendor strategy. CEO Ralph Andretta and CFO Perry Beberman present the AI programme to investors.

## Sources (10)

1. Bread Financial Holdings, Inc. Form 10-K for the fiscal year ended December 31, 2025 — Bread Financial Holdings (SEC filing), Feb 13, 2026. https://www.sec.gov/Archives/edgar/data/1101215/000110121526000016/bfh-20251231.htm
2. Bread Financial Holdings, Inc. Form 10-Q for the quarterly period ended June 30, 2026 — Bread Financial Holdings (SEC filing), Jul 28, 2026. https://www.sec.gov/Archives/edgar/data/1101215/000110121526000074/bfh-20260630.htm
3. Bread cuts expenses as charge-offs rise sharply — American Banker, Jan 25, 2024. https://americanbanker.com/payments/news/bread-cuts-expenses-as-charge-offs-rise-sharply
4. Strategic Moves and Market Insights By Investing.com (Bread Financial at the Barclays 23rd Annual Global Financial Services Conference) — Investing.com, Sep 9, 2025. https://investing.com/news/transcripts/bread-financial-at-barclays-conference-strategic-moves-and-market-insights-93CH-4231903
5. Earnings call transcript: Bread Financial Q4 2025 beats EPS expectations — Investing.com, Feb 3, 2026. https://investing.com/news/transcripts/earnings-call-transcript-bread-financial-q4-2025-beats-eps-expectations-93CH-4481011
6. Bread Financial at Bank of America Conference: Strategic Growth and Innovation — Investing.com, Feb 10, 2026. https://investing.com/news/transcripts/bread-financial-at-bank-of-america-conference-strategic-growth-and-innovation-93CH-4498295
7. Amid the 'SaaSpocalypse,' CIOs and CTOs take a harder line with their vendors — Fortune, Apr 8, 2026. https://fortune.com/2026/04/08/amid-the-saaspocalypse-cios-and-ctos-take-a-harder-line-with-their-vendors
8. Earnings call transcript: Bread Financial Q1 2026 beats expectations with strong growth — Investing.com, Apr 23, 2026. https://investing.com/news/transcripts/earnings-call-transcript-bread-financial-q1-2026-beats-expectations-with-strong-growth-93CH-4632777
9. Earnings call transcript: Bread Financial tops Q2 2026 estimates on strong credit sales — Investing.com, Jul 23, 2026. https://investing.com/news/transcripts/earnings-call-transcript-bread-financial-tops-q2-2026-estimates-on-strong-credit-sales-93CH-4809145
10. Large Commercial Banks (data as of June 30, 2026) — Federal Reserve Board, Oct 2, 2026. https://www.federalreserve.gov/releases/lbr/current/

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