A conservative California commercial bank whose public AI record is a policy framework, an AI Governance Council and 'selective and limited' use, not product announcements.
How is Citizens Business Bank using AI?
CVB Financial Corp., the Ontario, California holding company for Citizens Business Bank, N.A. (Federal Reserve rank 92, $21,183 million in bank assets at 30 June 2026), discloses AI mainly through governance rather than product announcements. Its FY2025 10-K, filed on 27 February 2026, adds a risk factor on the development and use of AI and says the bank has adopted an AI Policy governing AI and generative AI initiatives, including those involving vendors; its April 2026 proxy statement says the bank and certain vendors use AI tools on a selective and limited basis, to flag departures from known patterns in customer banking transactions and to prepare initial versions of training, marketing and research materials, under a Policy Framework and an AI Governance Council chaired by the Chief Operating Officer. The FY2024 10-K contained no reference to AI, and none of the bank's last four earnings calls, from Q3 2025 to Q2 2026, included an AI remark. The bank became a national bank on 15 December 2025, making the OCC its primary federal regulator, and completed its merger with Heritage Commerce Corp on 17 April 2026.
Thin public record: no AI remark on its last four earnings calls (Q3 2025 to Q2 2026), no named AI leader or platform, and AI disclosure limited to a 10-K risk factor and AI policy language in the proxy statement; its FY2024 10-K had no reference to AI.
Lead bank
Citizens Business Bank, N.A.
Assets (lead bank, Jun 30, 2026)
$21 billion
Charter
National bank since 15 December 2025 (OCC primary federal regulator; Federal Reserve member; FDIC deposit insurer); holding company supervised by the Federal Reserve
Headquarters
Ontario, CA
AI leadership
David A. Brager · David C. Harvey · Mike K. Currie · Rudy I. Ramirez
- Governance first: the FY2025 10-K says the bank has adopted an AI Policy establishing a governance framework for developing, deploying and managing AI and generative AI solutions, including those involving vendors, and the 2026 proxy statement describes a Policy Framework that applies to all AI initiatives of the bank and its vendors.
- A named oversight body: the AI Governance Council is chaired by the Chief Operating Officer and includes the Chief Information Officer, the CISO, the Human Resource Director, the Deputy Chief Credit Officer and an Associate General Counsel; it reviews and approves AI solutions, defines acceptable use and provides for regular monitoring and reporting.
- Use is described as limited: the proxy says the bank and certain vendors presently use AI tools on a selective and limited basis, including to track and flag departures from known patterns in customer banking transactions and, in specific circumstances, to prepare initial versions of associate training, customer marketing and educational materials and initial research.
- The 10-K lists where AI could be deployed: fraud detection and prevention, cybersecurity, credit risk and underwriting, regulatory compliance, process automation, data analysis, and customer marketing and product customization, while warning of third-party model risk, bias, hallucination, opacity and AI-enabled fraud by bad actors.
- Calls are silent on AI: across the Q3 2025 to Q2 2026 calls the CEO's technology remarks were about software expense and automation, such as software expense up 11% in Q3 2025, and the Q2 2026 call concerned the Heritage integration and acquisition expenses.
- Charter change matters: the bank converted from a California state bank to a national bank on 15 December 2025, so OCC model-risk and third-party guidance now apply directly, and the 10-K records the OCC as primary federal regulator.
What has Citizens Business Bank done on AI, and when?
- Jul 23, 2026
- Apr 17, 2026
Heritage Commerce merger completed[6][9]
CVB completed its acquisition of Heritage Commerce Corp and merged Heritage Bank of Commerce into Citizens Business Bank, N.A.; on the Q2 2026 call management reported $31.4 million of acquisition expenses and the integration of the two banks' core banking systems at the end of the second quarter.
- Apr 7, 2026
Proxy statement describes the AI Policy Framework and AI Governance Council[5]
The DEF 14A describes selective and limited AI use, a Policy Framework applying to the bank and its vendors, and an AI Governance Council chaired by the Chief Operating Officer.
- Feb 27, 2026
FY2025 10-K adds an AI risk factor and AI Policy[4]
The annual report adds a risk factor on the development and use of AI, says the bank has adopted an AI Policy governing AI and generative AI initiatives including those involving vendors, and lists areas where AI may be deployed.
- Jan 22, 2026
Q4 2025 call: software expense is the one expense line still growing[7]
CEO David Brager said the only expense line growing more than very low single digits on a full-year basis was technology, specifically software expense, and that the bank would continue to invest in it; the call contained no AI remark.
- Dec 17, 2025
Heritage Commerce merger agreement signed[3]
CVB and Heritage Commerce Corp entered into a merger agreement under which Heritage Bank of Commerce would merge into Citizens Business Bank, N.A.
- Dec 15, 2025
Bank converts to a national charter[4]
Citizens Business Bank converted from a California-chartered bank to a national banking association, making the OCC its primary federal regulator.
- Oct 23, 2025
Q3 2025 call: investment in technology and automation[2]
CEO David Brager said continued investment in technology infrastructure and automation lifted software expense $440,000, or 11%, from the third quarter of 2024; in Q&A management said technology is the one area where spending would continue and that it includes automation and cybersecurity.
- Feb 28, 2025
FY2024 10-K filed with no reference to AI[1]
CVB's annual report for 2024 contained no mention of artificial intelligence, generative AI or machine learning, a baseline against which the FY2025 disclosures stand out.
Where does Citizens Business Bank use AI today?
| System | What it does | Status | Use case |
|---|---|---|---|
| AI flagging of departures from known transaction patterns[5] | The bank and certain vendors use AI tools to enhance the security of certain customer banking transactions by tracking and flagging departures from known patterns. | In production | Fraud detection |
| Initial drafts of training, marketing and research[5] | In specific circumstances AI is used to prepare initial versions of associate training and customer marketing and educational materials or to perform initial research on topics relevant to banking operations. | In production | Generative & agentic AI |
| AI Policy, Policy Framework and AI Governance Council[5][4] | The Council, chaired by the COO with the CIO, CISO, Human Resource Director, Deputy Chief Credit Officer and an Associate General Counsel, reviews and approves AI solutions of the bank or its vendors, defines acceptable use and provides for monitoring and reporting. | In production | AI governance (general) |
Use-case links open the tracker's rules-by-use-case matrix: which documents govern each system type.
What has Citizens Business Bank disclosed in numbers?
“One area of expense growth is our continued investment in technology infrastructure and automation, which resulted in $440,000 or 11% growth in software expense from the third quarter of 2024.”[2]
David Brager · President and CEO · Oct 23, 2025
Who runs AI at Citizens Business Bank?
Which regulators govern Citizens Business Bank's AI?
| Authority | Why it matters here | Documents |
|---|---|---|
| OCC | Since 15 December 2025 Citizens Business Bank, N.A. is a national bank supervised by the OCC, so the revised model risk guidance and third-party risk guidance apply to its AI Policy and vendor-supplied AI. | OCC Bulletin 2026-13 OCC Bulletin 2023-17 |
| Federal Reserve | Holding-company supervisor, and the bank is a Federal Reserve System member; SR 26-2 on model risk covers the models behind AI-flagged transaction monitoring. | SR 26-2 |
| FDIC | Deposit insurer; the interagency model risk guidance was issued by the FDIC as FIL-15-2026. | FDIC FIL-15-2026 |
| California CPPA | California-based business: the proxy statement says the bank seeks to comply with the California Consumer Privacy Act and Privacy Rights Act, and the CPPA's automated decision-making regulations apply to covered uses. | CPPA ADMT, risk-assessment and cybersecurity-audit regulations |
What does the public record suggest about Citizens Business Bank's AI strategy?
Analysis by BankingNewsAI from the sources cited on this page. Observations, not advice.
01
Policy ahead of product
CVB wrote the AI Policy, a Policy Framework and a cross-functional Council before describing any named tool. For a bank that has just converted charters and absorbed Heritage, that sequencing keeps AI inside the model-risk and vendor-management perimeter the OCC now examines.
02
The first disclosure is a risk factor, not a result
The FY2024 10-K had no AI reference and the FY2025 10-K added a full risk factor plus the policy statement; the next filings will show whether any use case graduates from 'selective and limited' to a disclosed programme.
03
Earnings calls are the missing channel
Four consecutive calls without an AI remark, while the CEO cited software and automation spending, suggest management is not yet attributing efficiency to AI; that would change if the integrated bank's expense plan starts to cite it.
Does Citizens Business Bank use AI?
In a limited way, according to its 2026 proxy statement: the bank and certain vendors use AI tools on a selective and limited basis, including to flag departures from known patterns in customer banking transactions and, in specific circumstances, to prepare initial versions of training, marketing and educational materials or perform initial research.
Who governs AI at CVB Financial?
The bank has an AI Governance Council chaired by the Chief Operating Officer (David C. Harvey is listed as COO) that includes the Chief Information Officer, the CISO, the Human Resource Director, the Deputy Chief Credit Officer and an Associate General Counsel, operating under a Policy Framework and AI Policy that apply to the bank and its vendors.
Has CVB Financial talked about AI on its earnings calls?
Not in the four calls from Q3 2025 to Q2 2026. The Q3 2025 call mentioned continued investment in technology infrastructure and automation, with software expense up 11% year over year, and the Q2 2026 call focused on integrating Heritage Commerce.
What does CVB's 10-K say about AI?
The FY2025 10-K adds a risk factor saying the bank or its vendors may incorporate AI into areas such as fraud detection, cybersecurity, credit risk and underwriting, regulatory compliance, process automation, data analysis and customer marketing, that it has adopted an AI Policy, and that AI models can produce incorrect or biased output and expose it to legal and reputational harm. The FY2024 10-K had no reference to AI.
- CVB Financial Corp. Annual Report on Form 10-K for the fiscal year ended December 31, 2024
- CVB Financial Corporation (CVBF) Q3 FY2025 earnings call transcript
- CVB Financial Corp. Form 8-K: Agreement and Plan of Reorganization and Merger with Heritage Commerce Corp
- CVB Financial Corp. Annual Report on Form 10-K for the fiscal year ended December 31, 2025
- CVB Financial Corp. Definitive Proxy Statement (DEF 14A) for the 2026 annual meeting
- CVB Financial Corp. Form 8-K: Completion of acquisition of Heritage Commerce Corp
- CVB Financial Corporation (CVBF) Q4 FY2025 earnings call transcript
- CVB Financial Corporation (CVBF) Q1 FY2026 earnings call transcript
- CVB Financial Corp. (BCV.F) Q2 FY2026 earnings call transcript
- CVB Financial Corp. Form 10-Q for the quarterly period ended June 30, 2026
- Leadership Team (undated page, retrieved 2026-10-05)
- Large Commercial Banks (data as of June 30, 2026)
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