SEC filings · computed from SEC EDGAR filings dataset; nothing on this page is written by a model. All ranked answers: /banks/leaders
On the public record as of Oct 31, 2026, 43 of the 141 large banks profiled have a verbatim AI statement in the management's discussion and analysis of a 10-K or 10-Q. Ranked by quotes (filings), the top 5 are Zions (11 filing quotes), State Street (10 filing quotes), Goldman (9 filing quotes), Huntington (8 filing quotes) and Truist (8 filing quotes). Zions's strongest evidence: Zions lists adoption and integration of AI among emerging technology risks that could affect its results. (Form 10-Q, MD&A, filed Aug 6, 2026).
141 banks profiled (120 US, 21 non-US) · 43 with matching evidence · top 40 shown · ranked answer, not a comparison
Which of the large banks discuss AI in the MD&A of their filings?
| # | Bank | Quotes (filings) | Latest statement (extractor's one-line claim) | Status | Date | On this site | Sources |
|---|---|---|---|---|---|---|---|
| 1 | Zions | 11 | Zions lists adoption and integration of AI among emerging technology risks that could affect its results. (Form 10-Q, MD&A, filed Aug 6, 2026) | 7 filings | Aug 6, 2026 | Zions · in their words → | SEC EDGAR ↗ · SEC EDGAR ↗ |
| 2 | State Street | 10 | State Street warns that frontier AI models amplify cybersecurity, social engineering and fraud risks that could hurt its operations and financial results. (Form 10-Q, MD&A, filed Jul 30, 2026) | 7 filings | Jul 30, 2026 | State Street · in their words → | SEC EDGAR ↗ · SEC EDGAR ↗ |
| 3 | Goldman | 9 | Goldman has a Firmwide Artificial Intelligence Risk Committee overseeing AI-use risks, co-chaired by its CIO and chief risk officer. (Form 10-Q, MD&A, filed Aug 3, 2026) | 6 filings | Aug 3, 2026 | Goldman · in their words → | SEC EDGAR ↗ · SEC EDGAR ↗ |
| 4 | Huntington | 8 | Huntington has a dedicated Artificial Intelligence Risk Committee among its management committees overseeing risk. (Form 10-Q, MD&A, filed Jul 28, 2026) | 7 filings | Jul 28, 2026 | Huntington · in their words → | SEC EDGAR ↗ · SEC EDGAR ↗ |
| 5 | Truist | 8 | Truist says its Model Risk Oversight unit independently validates all decision models, including trading market risk models. (Form 10-Q, MD&A, filed May 1, 2026) | 5 filings | May 1, 2026 | Truist · in their words → | SEC EDGAR ↗ · SEC EDGAR ↗ |
| 6 | Amex | 7 | Amex warns that cyberattacks it faces include AI-assisted deepfakes and attacks exploiting vulnerabilities in AI models. (Form 10-Q, MD&A, filed Oct 23, 2026) | 6 filings | Oct 23, 2026 | Amex · in their words → | SEC EDGAR ↗ · SEC EDGAR ↗ |
| 7 | BOK Financial | 7 | BOK Financial says its Model Risk Management unit enforces model governance and can require remediation or restrict model usage. (Form 10-Q, MD&A, filed Aug 4, 2026) | 4 filings | Aug 4, 2026 | BOK Financial · in their words → | SEC EDGAR ↗ · SEC EDGAR ↗ |
| 8 | Synchrony | 7 | Synchrony says agentic AI shopping agents could autonomously handle purchases, threatening its relationships with consumers and merchants if competitors gain advantaged… (Form 10-K, MD&A, filed Feb 6, 2026) | 3 filings | Feb 6, 2026 | Synchrony · in their words → | SEC EDGAR ↗ · SEC EDGAR ↗ |
| 9 | Morgan Stanley | 6 | Morgan Stanley says AI adoption is supporting active capital markets and improved investor sentiment in the second quarter of 2026. (Form 10-Q, MD&A, filed Aug 4, 2026) | 5 filings | Aug 4, 2026 | Morgan Stanley · in their words → | SEC EDGAR ↗ · SEC EDGAR ↗ |
| 10 | Fifth Third | 6 | Fifth Third's Model Risk Committee, under the Operational Risk Committee, governs model and information security risks. (Form 10-K, MD&A, filed Feb 24, 2026) | 4 filings | Feb 24, 2026 | Fifth Third · in their words → | SEC EDGAR ↗ · SEC EDGAR ↗ |
| 11 | Ally | 6 | Ally says frontier and emerging AI models are rapidly raising the speed, scale, and complexity of cyber threats across financial services. (Form 10-Q, MD&A, filed Jul 23, 2026) | 3 filings | Jul 23, 2026 | Ally · in their words → | SEC EDGAR ↗ · SEC EDGAR ↗ |
| 12 | Citi | 6 | Citi's credit loss reserve qualitative adjustments account for risks from AI to vulnerable sectors that the quantitative model does not fully capture. (Form 10-Q, MD&A, filed May 7, 2026) | 3 filings | May 7, 2026 | Citi · in their words → | SEC EDGAR ↗ · SEC EDGAR ↗ |
| 13 | Schwab | 5 | Schwab says it manages AI model risk through policies, controls, and cross-functional review before any AI is used. (Form 10-K, MD&A, filed Feb 25, 2026) | 3 filings | Feb 25, 2026 | Schwab · in their words → | SEC EDGAR ↗ · SEC EDGAR ↗ |
| 14 | Community Bank N.A. | 4 | Data processing cost increases reflect the company's continued investment in AI applications and workflow efficiency technologies. (Form 10-Q, MD&A, filed May 8, 2026) | 3 filings | May 8, 2026 | Community Bank N.A. · in their words → | SEC EDGAR ↗ · SEC EDGAR ↗ |
| 15 | JPMorgan | 4 | JPMorgan says it has seen rising cyber attacks and expects more, with attackers using emerging technologies including AI. (Form 10-K, MD&A, filed Feb 13, 2026) | 3 filings | Feb 13, 2026 | JPMorgan · in their words → | SEC EDGAR ↗ · SEC EDGAR ↗ |
| 16 | Eastern Bank | 4 | Eastern uses a quantitative loan rating model for CECL-style lifetime loss estimates, with qualitative overlays to address model risk. (Form 10-Q, MD&A, filed Aug 8, 2025) | 3 filings | Aug 8, 2025 | Eastern Bank · in their words → | SEC EDGAR ↗ · SEC EDGAR ↗ |
| 17 | HSBC USA | 4 | HSBC USA defines model risk as the potential for adverse consequences from model errors or inappropriate use of modelled outputs in business decisions. (Form 10-Q, MD&A, filed Apr 29, 2025) | 3 filings | Apr 29, 2025 | HSBC USA · in their words → | SEC EDGAR ↗ · SEC EDGAR ↗ |
| 18 | Trustmark | 4 | Trustmark says business investment, including AI infrastructure spending, supported economic activity in the first half of 2026. (Form 10-Q, MD&A, filed Aug 5, 2026) | 2 filings | Aug 5, 2026 | Trustmark · in their words → | SEC EDGAR ↗ · SEC EDGAR ↗ |
| 19 | SoFi | 3 | SoFi acquired AI-powered investing platform Composer to make advanced investing tools more accessible to members. (Form 10-Q, MD&A, filed Aug 6, 2026) | 3 filings | Aug 6, 2026 | SoFi · in their words → | SEC EDGAR ↗ · SEC EDGAR ↗ |
| 20 | BNY | 3 | BNY says its model risk framework covers AI and large language model use cases and is part of a broader cross-functional AI risk management framework. (Form 10-K, MD&A, filed Feb 25, 2026) | 2 filings | Feb 25, 2026 | BNY · in their words → | SEC EDGAR ↗ · SEC EDGAR ↗ |
| 21 | Northern Trust | 3 | Northern Trust applies its model risk framework, including independent validation and monitoring, to AI and machine learning models. (Form 10-K, MD&A, filed Feb 24, 2026) | 2 filings | Feb 24, 2026 | Northern Trust · in their words → | SEC EDGAR ↗ · SEC EDGAR ↗ |
| 22 | The Bancorp | 2 | The Bancorp says it is investing in AI tools to gain efficiency and productivity across its people and platform. (Form 10-Q, MD&A, filed May 6, 2026) | 2 filings | May 6, 2026 | The Bancorp · in their words → | SEC EDGAR ↗ · SEC EDGAR ↗ |
| 23 | SouthState | 2 | SouthState cites technology changes including AI as a risk, along with disruption to its business model and lacking resources to match competitors' technology… (Form 10-Q, MD&A, filed May 1, 2026) | 2 filings | May 1, 2026 | SouthState · in their words → | SEC EDGAR ↗ · SEC EDGAR ↗ |
| 24 | First Horizon | 2 | First Horizon assigns trading risk management personnel primary responsibility for model risk management of its VaR model. (Form 10-K, MD&A, filed Feb 26, 2026) | 2 filings | Feb 26, 2026 | First Horizon · in their words → | SEC EDGAR ↗ · SEC EDGAR ↗ |
| 25 | Citizens | 2 | Citizens' Model Risk Management and Validation team independently challenges market risk model assumptions, techniques and data soundness. (Form 10-K, MD&A, filed Feb 12, 2026) | 2 filings | Feb 12, 2026 | Citizens · in their words → | SEC EDGAR ↗ · SEC EDGAR ↗ |
| 26 | Raymond James | 2 | Raymond James says model errors or misuse could cause significant financial loss and inaccurate reporting, with models used for valuation, credit allowances and stress… (Form 10-K, MD&A, filed Nov 25, 2025) | 2 filings | Nov 25, 2025 | Raymond James · in their words → | SEC EDGAR ↗ · SEC EDGAR ↗ |
| 27 | PNC | 2 | PNC names a sudden reversal in AI-related sentiment as a risk to its growth and inflation outlook, with knock-on effects on capex and consumer spending. (Form 10-Q, MD&A, filed Aug 5, 2026) | 1 filing | Aug 5, 2026 | PNC · in their words → | SEC EDGAR ↗ |
| 28 | Hancock Whitney | 1 | Hancock Whitney's macro outlook cites continued business investment in AI technology as a driver of second-quarter 2026 U.S. GDP growth. (Form 10-Q, MD&A, filed Aug 7, 2026) | 1 filing | Aug 7, 2026 | Hancock Whitney · in their words → | SEC EDGAR ↗ |
| 29 | Seacoast Bank | 1 | Seacoast flags risks and costs from developing and using AI and emerging technologies, including data privacy, model accuracy, and regulatory compliance. (Form 10-Q, MD&A, filed Aug 4, 2026) | 1 filing | Aug 4, 2026 | Seacoast Bank · in their words → | SEC EDGAR ↗ |
| 30 | Central Bank | 1 | Central Bank says it monitors AI-related cybersecurity and fraud risks, which did not materially affect results this quarter. (Form 10-Q, MD&A, filed May 15, 2026) | 1 filing | May 15, 2026 | Central Bank · in their words → | SEC EDGAR ↗ |
| 31 | First Citizens | 1 | First Citizens lists the impact of artificial intelligence on various industries among emerging risks it assesses on an ongoing basis. (Form 10-Q, MD&A, filed May 8, 2026) | 1 filing | May 8, 2026 | First Citizens · in their words → | SEC EDGAR ↗ |
| 32 | BancFirst | 1 | BancFirst lists artificial intelligence among technological changes and fintech disruption that could affect its traditional banking business. (Form 10-Q, MD&A, filed May 8, 2026) | 1 filing | May 8, 2026 | BancFirst · in their words → | SEC EDGAR ↗ |
| 33 | Wells Fargo | 1 | Wells Fargo says recent AI advances make it easier to find and exploit cybersecurity vulnerabilities, raising information security risk for customers and industries. (Form 10-Q, MD&A, filed Apr 29, 2026) | 1 filing | Apr 29, 2026 | Wells Fargo · in their words → | SEC EDGAR ↗ |
| 34 | OceanFirst | 1 | OceanFirst says its technology investment incorporates AI into processing to support growth and operational efficiency. (Form 10-K, MD&A, filed Feb 27, 2026) | 1 filing | Feb 27, 2026 | OceanFirst · in their words → | SEC EDGAR ↗ |
| 35 | NBT | 1 | NBT expects continued heavy AI and infrastructure investment to be a primary driver of business investment and growth in 2026. (Form 10-K, MD&A, filed Feb 27, 2026) | 1 filing | Feb 27, 2026 | NBT · in their words → | SEC EDGAR ↗ |
| 36 | FNB | 1 | FNB says its investments in technology, AI and data analytics are driving automation, efficiency and positive operating leverage. (Form 10-K, MD&A, filed Feb 24, 2026) | 1 filing | Feb 24, 2026 | FNB · in their words → | SEC EDGAR ↗ |
| 37 | Busey Bank | 1 | Busey lists technological changes, including AI tools developed by it or third-party vendors, as a factor that could cause results to differ materially. (Form 10-Q, MD&A, filed Aug 5, 2025) | 1 filing | Aug 5, 2025 | Busey Bank · in their words → | SEC EDGAR ↗ |
| 38 | Beacon Bank | 1 | Beacon lists the emergence of AI technology among its emerging IT and cyber risks in its 2024 corporate risk assessment. (Form 10-K, MD&A, filed Mar 3, 2025) | 1 filing | Mar 3, 2025 | Beacon Bank · in their words → | SEC EDGAR ↗ |
| 39 | BofA | 1 | BofA says it has put internal processes and governance frameworks in place to manage AI risks and responsible use. (Form 10-K, MD&A, filed Feb 25, 2025) | 1 filing | Feb 25, 2025 | BofA · in their words → | SEC EDGAR ↗ |
| 40 | Rockland Trust | 1 | Independent Bank states its operational risk definition includes model risk, with exposure existing throughout the company. (Form 10-K, MD&A, filed Feb 28, 2024) | 1 filing | Feb 28, 2024 | Rockland Trust · in their words → | SEC EDGAR ↗ |
Each row quotes one record from SEC EDGAR filings dataset; the “On this site” link opens the bank's own page or sub-page with every source. Banks absent from the table have nothing matching on the record this site holds.
How is this ranked?
Data: the SEC filings dataset (data/sec/quotes.jsonl): verbatim AI statements from 10-K, 10-Q, 8-K and DEF 14A filings of the banks' holding companies, each with its EDGAR link, filing date, section and topic.
Rule: Quotes from the MD&A section. Score = such quotes; ties by distinct filings, then the newest filing.
Counts: 43 of 141 profiled banks qualify; the table shows the top 40; 66 distinct sources cited in the table. Data checked 2026-10-31; ranking template updated 2026-10-30.
What are the caveats?
The dataset holds the AI passages the extractor found in filings since January 2024; a bank with few quotes may say more in passages not captured. Quotes are verbatim; the one-line claim is the extractor's summary and links the EDGAR text.
Banks without a US SEC filer (most non-US groups, private and mutual banks) have no quotes and are absent.
Banks absent from the table have nothing matching on the record this site holds, which is not evidence that they do nothing. Each row links the bank's own page, where every entry carries its sources.
Which bank ranks first?
Zions Bancorporation leads with 11 filing quotes: Zions lists adoption and integration of AI among emerging technology risks that could affect its results. (Form 10-Q, MD&A, filed Aug 6, 2026). State Street is second with 10.
How many large banks discuss AI in MD&A?
43 of the 141 profiled banks (120 US, 21 non-US groups); the table shows the top 40. Among those listed, 40 are US banks and 0 non-US groups.
What counts, and what does not?
Quotes from the MD&A section. Score = such quotes; ties by distinct filings, then the newest filing. Source: the SEC filings dataset (data/sec/quotes.jsonl): verbatim AI statements from 10-K, 10-Q, 8-K and DEF 14A filings of the banks' holding companies, each with its EDGAR link, filing date, section and topic.
Is this a measure of capability?
No. Every row is a sourced fact on the public record: what the bank, a regulator, a filing or an independent outlet has put on the record. The page does not rate how well anything works.
When was this checked, and how often does it update?
The data behind the table was last checked on 2026-10-31 (SEC EDGAR filings dataset). The page recomputes whenever that dataset changes and is republished with the site; it is never edited by hand.
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