Which large banks use AI for model risk management of AI models?

Data checked Oct 28, 2026 · 116 of 141 banks qualify · 69 sources cited · template updated Oct 30, 2026

AI use cases · computed from bank profiles; nothing on this page is written by a model. All ranked answers: /banks/leaders

On the public record as of Oct 28, 2026, 116 of the 141 large banks profiled describe at least one sourced AI use case for model risk management of AI models on their profile. Ranked by use cases (in production), the top 5 are Sallie Mae (3 use cases), Standard Chartered (3 use cases), Beacon Bank (2 use cases), M&T (2 use cases) and Raymond James (2 use cases). Sallie Mae's strongest evidence: AI as a credit-risk variable: Management tracks AI's effect on graduate employment and cosigner strength, discussed on the January and April 2026….

141 banks profiled (120 US, 21 non-US) · 116 with matching evidence · top 40 shown · ranked answer, not a comparison

Which of the large banks use AI for model risk management of AI models?

Checked 2026-10-28 · bank profiles
#BankUse cases (in production)Strongest use caseStatusDateOn this siteSources
1Sallie Mae3AI as a credit-risk variable: Management tracks AI's effect on graduate employment and cosigner strength, discussed on the January and April 2026…In production (3 of 3 in production)Apr 23, 2026Sallie Mae profile →The Motley Fool (Yahoo Finance) ↗ · Investing.com ↗
2Standard Chartered3AI Safety Council and tiered evaluation of AI systems: The 2025 annual report says the council evaluates AI solutions before use, systems are assessed in proportion to their…In production (2 of 3 in production)Feb 24, 2026Standard Chartered profile →Standard Chartered PLC ↗ · Standard Chartered PLC ↗
3Beacon Bank2Vendor-built credit-loss models on one allowance process: After the February 2026 core conversion the allowance became a single integrated processIn production (2 of 2 in production)Aug 7, 2026Beacon Bank profile →Beacon Financial (SEC filings) ↗ · Beacon Financial (SEC filings) ↗
4M&T2AI Risk Oversight (second line): Independent oversight program for responsible AI adoptionIn production (2 of 2 in production)Jul 23, 2026M&T profile →American Banker ↗ · M&T Bank (SEC filings) ↗
5Raymond James2Model governance gate before production: Per the firm, no AI innovation moves from Carillon Labs into production until model governance teams have tested and…In production (2 of 2 in production)Jun 8, 2026Raymond James profile →Raymond James Financial (SEC filings) ↗ · Raymond James ↗
6WesBanco2Model risk management under the Chief Risk Officer: Nathan Jones, in post since 27 April 2026, is responsible for model risk management alongside risk management…In production (2 of 2 in production)Apr 24, 2026WesBanco profile →WesBanco (SEC filings) ↗ · WesBanco ↗
7Banner Bank2Model Risk team under the Chief Risk Officer: The Model Risk function sits in Dan Oxford's remit with Enterprise Risk, Compliance, Fraud and Vendor Risk, reporting…In production (2 of 2 in production)Apr 6, 2026Banner Bank profile →Banner Corporation (SEC filings) ↗ · Banner Bank ↗
8Renasant2Enterprise risk committee oversight of AI use: The board ERM committee and technology committee 'oversee risks related to our technological infrastructure, use of…In production (2 of 2 in production)Mar 18, 2026Renasant profile →Renasant Corporation (SEC filings) ↗ · Renasant Corporation (SEC filings) ↗
9Huntington2AI risk factor, AI Risk Committee and board oversight: 10-K risk factor on flawed, biased or misleading model output and evolving AI lawIn production (2 of 2 in production)Mar 12, 2026Huntington · responsible ai →Huntington Bancshares (SEC filing) ↗ · Huntington Bancshares (SEC filing) ↗
10First Hawaiian2AI risk-factor disclosure: Stand-alone 10-K risk factor covering evolving AI regulation, incorrect or biased generative-AI output, model opacity…In production (2 of 2 in production)Feb 27, 2026First Hawaiian profile →First Hawaiian, Inc. (SEC filings) ↗ · Zest AI (vendor case study) ↗
11Truist2AI risk management on the NIST AI RMF: 10-K AI risk factor on flawed, biased or degraded models and third-party AI servicesIn production (2 of 2 in production)Feb 24, 2026Truist · responsible ai →Truist Financial (SEC filing) ↗ · American Banker ↗
12FNB2AI and generative-AI risk factor: The 10-K flags inaccurate or biased generative-AI output, dependence on data quality and model governance, third-party…In production (2 of 2 in production)Feb 24, 2026FNB · responsible ai →F.N.B. Corporation ↗ · F.N.B. Corporation (SEC filings) ↗
13SouthState2Formal AI Strategy and AI risk-factor disclosure: The 10-K records a formal AI Strategy with controls to maintain accuracy and reduce or eliminate bias, and lists…In production (2 of 2 in production)Feb 20, 2026SouthState · responsible ai →American Banker ↗ · SouthState Bank Corporation (SEC filings) ↗
14Barclays US2Group AI and machine-learning risk factor: Barclays PLC's 20-F risk factor on generative and agentic AI and ML covers third-party providers' AI use and evolving…In production (2 of 2 in production)Feb 10, 2026Barclays US profile →SEC (Barclays PLC 20-F) ↗
15Barclays2AI Policy, AI Standard and Group AI Governance Council: Defines Ethical AI Principles and risk tiers for AI useIn production (2 of 2 in production)Feb 10, 2026Barclays profile →Barclays PLC (SEC 20-F) ↗
16Amex2AI risk-factor disclosure: 10-K covers agentic-commerce disintermediation, flawed or biased models, hallucinations and the EU AI Act and US state…In production (2 of 2 in production)Feb 6, 2026Amex profile →American Express (SEC filings) ↗ · VentureBeat ↗
17Ally2AI risk-factor disclosure: The 10-K covers incorrect or biased output from generative AI and agents, explainability, third-party and…In production (1 of 2 in production)Jul 23, 2026Ally · responsible ai →Ally Financial (SEC filings) ↗ · Ally Financial (SEC filings) ↗
18Banco Santander2Model-risk scope extended to AI systems: The annual report describes expansion of model-risk management to cover AI systems and promotion of compliance with…In production (1 of 2 in production)Feb 26, 2026Banco Santander profile →Banco Santander ↗ · Banco Santander ↗
19BMO Financial Group2AI risk directive, Responsible AI Forum and model validation: Life-cycle standards for every AI initiative, pre-implementation review of significant ones by a cross-functional…In production (1 of 2 in production)Dec 4, 2025BMO Financial Group profile →Bank of Montreal (SEC filing) ↗ · American Banker ↗
20Prosperity2AI risk language in quarterly filings: Each 10-Q from Q3 2025 to Q2 2026 lists risks from new technologies including AI and machine learning among…Announced (0 of 2 in production)Aug 6, 2026Prosperity profile →Prosperity Bancshares (SEC filings) ↗ · Prosperity Bancshares (SEC filings) ↗
21CIBC1AI and ML in the model inventory; AI governance committees: Model-risk governance covers AI and ML models ahead of OSFI Guideline E-23 (May 2027)In productionAug 27, 2026CIBC profile →CIBC ↗ · CIBC ↗
22Axos Bank1AI risk-factor disclosure: 10-K covers agentic and generative AI, third-party model dependence, bias, explainability and evolving regulationIn productionAug 20, 2026Axos Bank profile →SEC EDGAR ↗
23Central Bank1AI in 10-K risk factors and 10-Q risk monitoring: AI named as a source of implementation errors and fraud or cyber riskIn productionAug 14, 2026Central Bank profile →Central Bancompany (SEC filings) ↗ · Central Bancompany (SEC filings) ↗
24Commonwealth Bank1Group AI Policy, Standard and AI Risk Committee: A Group AI Policy and Standard, six responsible AI principles, GenAI guardrails, AI Risk Indicators in the Group Risk…In productionAug 12, 2026Commonwealth Bank · responsible ai →Commonwealth Bank of Australia ↗ · Commonwealth Bank of Australia ↗
25Cathay Bank1Technology-change risk factor (no AI reference): The 10-K frames technology risk as implementation cost, disruption and better-resourced competitors, without…In productionAug 7, 2026Cathay Bank profile →Cathay General Bancorp (SEC filings) ↗ · Cathay General Bancorp (SEC filings) ↗
26ServisFirst Bank1AI-enabled tools in financial-reporting controls: Used to support identification, validation and consistent classification of cash-flow activities after a material…In productionAug 7, 2026ServisFirst Bank profile →ServisFirst Bancshares (SEC filings) ↗
27Goldman1AI risk factor and Firmwide AI Risk Committee: 10-K risk factor on generative-AI output, bias, opacity and third-party modelsIn productionAug 3, 2026Goldman · responsible ai →Goldman Sachs (SEC filing) ↗ · Goldman Sachs (SEC filing) ↗
28State Street1AI under the model risk management framework: 10-K: AI, generative AI and machine-learning models automate or enhance business processes, and AI and ML models used…In productionJul 30, 2026State Street profile →State Street (SEC filing) ↗ · State Street (SEC filing) ↗
29MUFG1MUFG AI Policy and AI risk management: A nine-principle AI Policy and, per the 20-F, a controls framework for appropriate, reliable and secure AI use that…In productionJul 6, 2026MUFG · responsible ai →Mitsubishi UFJ Financial Group, Inc. ↗ · Mitsubishi UFJ Financial Group, Inc. (SEC Form 20-F) ↗
30FNBO1Scoped access and staged adoption for vendor AI agents: Agents hold the same access privileges a human would in the Verafin system, run on jobs that are easy to explain, and…In productionJun 24, 2026FNBO profile →American Banker ↗
31Pinnacle1AI and complex-model risk disclosure: 10-K and 10-Q risk factors on accuracy, bias, explainability and compliance of AI and complex models, and on…In productionMay 6, 2026Pinnacle profile →Pinnacle Financial Partners (SEC filing) ↗ · Pinnacle Financial Partners (SEC filing) ↗
32Banc of California1AI risk factor and AI-disruption credit screen: 10-K risk factor on third-party AIIn productionApr 23, 2026Banc of California profile →SEC EDGAR ↗ · Yahoo Finance (Motley Fool transcript) ↗
33Lloyds1AI ethics principles, Data and AI Ethics Committee and AI Assurance Framework: Use cases are overseen by the Data and AI Ethics Committee and held in a central model and use-case inventoryIn productionApr 20, 2026Lloyds profile →Lloyds Banking Group (SEC filing) ↗ · Lloyds Banking Group ↗
34Mechanics Bank1AI risk-factor disclosure: The 10-K says the company uses AI on a limited basis and that flawed algorithms, biased datasets or deficient…In productionApr 16, 2026Mechanics Bank profile →Mechanics Bancorp (SEC filings) ↗ · Mechanics Bancorp (SEC filings) ↗
35Citizens Business Bank1AI Governance Council approval and monitoring of AI models: The Policy Framework and Council govern review and approval of AI solutions, regulate the development, deployment and…In productionApr 7, 2026Citizens Business Bank profile →CVB Financial Corp. (SEC filings) ↗ · CVB Financial Corp. (SEC filings) ↗
36Atlantic Union1AI and machine-learning models in use: Disclosed in the 10-K with training-data, bias and interpretability risksIn productionMar 25, 2026Atlantic Union profile →Atlantic Union Bankshares ↗
37First Horizon1AI risk factor and board oversight: The 10-K flags flawed, insufficient or biased datasets and non-transparent AI modelsIn productionMar 16, 2026First Horizon profile →First Horizon (SEC filings) ↗ · First Horizon (SEC filings) ↗
38Société Générale1AI risk and training controls: The registration document describes AI acculturation and training for all employees, a gap analysis of AI-specific…In productionMar 13, 2026Société Générale profile →Societe Generale ↗
39Deutsche Bank (U.S.)1Agentic-AI risk factor and AI control framework: The 20-F says AI risk is incorporated into the control framework and flags hallucination, bias, explainability, data…In productionMar 12, 2026Deutsche Bank (U.S.) · responsible ai →Deutsche Bank AG (SEC filings) ↗
40Deutsche Bank1AI risk inside the control framework: The 20-F says AI risk has been incorporated into the control framework and names hallucination, bias, explainability…In productionMar 12, 2026Deutsche Bank profile →Deutsche Bank AG (SEC filings) ↗

Each row quotes one record from bank profiles; 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 141 bank profiles on this site (lib/banks), every entry dated and sourced: the "Where AI runs" use cases, each with a status (in production, rolling out, pilot, announced).

Rule: Use cases tagged model-risk. Score = matching use cases. Order: matching use cases, then those in production, then the strongest stage, then the newest source.

Counts: 116 of 141 profiled banks qualify; the table shows the top 40; 69 distinct sources cited in the table. Data checked 2026-10-28; ranking template updated 2026-10-30.

What are the caveats?

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?

SLM Corporation (Sallie Mae) leads with 3 use cases: AI as a credit-risk variable: Management tracks AI's effect on graduate employment and cosigner strength, discussed on the January and April 2026…. Standard Chartered is second with 3.

How many large banks describe AI use cases for ai model risk?

116 of the 141 profiled banks (120 US, 21 non-US groups); the table shows the top 40. Among those listed, 31 are US banks and 9 non-US groups.

What counts, and what does not?

Use cases tagged model-risk. Score = matching use cases. Order: matching use cases, then those in production, then the strongest stage, then the newest source. Source: the 141 bank profiles on this site (lib/banks), every entry dated and sourced: the "Where AI runs" use cases, each with a status (in production, rolling out, pilot, announced).

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 2026-10-28 (bank profiles). The page recomputes whenever that dataset changes and is republished with the site; it is never edited by hand.

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