Which large banks discuss AI in the MD&A of their filings?

Data checked Oct 31, 2026 · 43 of 141 banks qualify · 66 sources cited · template updated Oct 30, 2026

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?

Checked 2026-10-31 · SEC EDGAR filings dataset
#BankQuotes (filings)Latest statement (extractor's one-line claim)StatusDateOn this siteSources
1Zions11Zions 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 filingsAug 6, 2026Zions · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
2State Street10State 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 filingsJul 30, 2026State Street · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
3Goldman9Goldman 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 filingsAug 3, 2026Goldman · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
4Huntington8Huntington has a dedicated Artificial Intelligence Risk Committee among its management committees overseeing risk. (Form 10-Q, MD&A, filed Jul 28, 2026)7 filingsJul 28, 2026Huntington · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
5Truist8Truist 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 filingsMay 1, 2026Truist · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
6Amex7Amex 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 filingsOct 23, 2026Amex · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
7BOK Financial7BOK 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 filingsAug 4, 2026BOK Financial · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
8Synchrony7Synchrony 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 filingsFeb 6, 2026Synchrony · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
9Morgan Stanley6Morgan 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 filingsAug 4, 2026Morgan Stanley · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
10Fifth Third6Fifth 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 filingsFeb 24, 2026Fifth Third · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
11Ally6Ally 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 filingsJul 23, 2026Ally · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
12Citi6Citi'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 filingsMay 7, 2026Citi · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
13Schwab5Schwab 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 filingsFeb 25, 2026Schwab · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
14Community Bank N.A.4Data 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 filingsMay 8, 2026Community Bank N.A. · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
15JPMorgan4JPMorgan 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 filingsFeb 13, 2026JPMorgan · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
16Eastern Bank4Eastern 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 filingsAug 8, 2025Eastern Bank · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
17HSBC USA4HSBC 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 filingsApr 29, 2025HSBC USA · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
18Trustmark4Trustmark 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 filingsAug 5, 2026Trustmark · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
19SoFi3SoFi 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 filingsAug 6, 2026SoFi · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
20BNY3BNY 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 filingsFeb 25, 2026BNY · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
21Northern Trust3Northern 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 filingsFeb 24, 2026Northern Trust · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
22The Bancorp2The 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 filingsMay 6, 2026The Bancorp · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
23SouthState2SouthState 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 filingsMay 1, 2026SouthState · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
24First Horizon2First 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 filingsFeb 26, 2026First Horizon · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
25Citizens2Citizens' 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 filingsFeb 12, 2026Citizens · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
26Raymond James2Raymond 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 filingsNov 25, 2025Raymond James · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
27PNC2PNC 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 filingAug 5, 2026PNC · in their words →SEC EDGAR ↗
28Hancock Whitney1Hancock 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 filingAug 7, 2026Hancock Whitney · in their words →SEC EDGAR ↗
29Seacoast Bank1Seacoast 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 filingAug 4, 2026Seacoast Bank · in their words →SEC EDGAR ↗
30Central Bank1Central 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 filingMay 15, 2026Central Bank · in their words →SEC EDGAR ↗
31First Citizens1First 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 filingMay 8, 2026First Citizens · in their words →SEC EDGAR ↗
32BancFirst1BancFirst 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 filingMay 8, 2026BancFirst · in their words →SEC EDGAR ↗
33Wells Fargo1Wells 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 filingApr 29, 2026Wells Fargo · in their words →SEC EDGAR ↗
34OceanFirst1OceanFirst says its technology investment incorporates AI into processing to support growth and operational efficiency. (Form 10-K, MD&A, filed Feb 27, 2026)1 filingFeb 27, 2026OceanFirst · in their words →SEC EDGAR ↗
35NBT1NBT 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 filingFeb 27, 2026NBT · in their words →SEC EDGAR ↗
36FNB1FNB 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 filingFeb 24, 2026FNB · in their words →SEC EDGAR ↗
37Busey Bank1Busey 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 filingAug 5, 2025Busey Bank · in their words →SEC EDGAR ↗
38Beacon Bank1Beacon 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 filingMar 3, 2025Beacon Bank · in their words →SEC EDGAR ↗
39BofA1BofA 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 filingFeb 25, 2025BofA · in their words →SEC EDGAR ↗
40Rockland Trust1Independent 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 filingFeb 28, 2024Rockland 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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