Which large banks discuss AI model risk in their SEC filings?

Data checked Oct 31, 2026 · 66 of 141 banks qualify · 80 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, 66 of the 141 large banks profiled have a verbatim filing statement classified under model risk. Ranked by quotes (filings), the top 5 are BOK Financial (12 filing quotes), State Street (9 filing quotes), Truist (6 filing quotes), Wells Fargo (6 filing quotes) and Huntington (5 filing quotes). BOK Financial's strongest evidence: 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).

141 banks profiled (120 US, 21 non-US) · 66 with matching evidence · top 40 shown · ranked answer, not a comparison

Which of the large banks discuss AI model risk in their SEC filings?

Checked 2026-10-31 · SEC EDGAR filings dataset
#BankQuotes (filings)Latest statement (extractor's one-line claim)StatusDateOn this siteSources
1BOK Financial12BOK 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)6 filingsAug 4, 2026BOK Financial · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
2State Street9State Street says model results influence its business decisions and model failure could harm its financial performance. (Form 10-Q, MD&A, filed Jul 30, 2026)8 filingsJul 30, 2026State Street · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
3Truist6Truist 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 ↗
4Wells Fargo6Wells Fargo notes that complex, opaque AI models make it hard to understand why they produce particular outputs. (Form 10-K, risk factors, filed Feb 24, 2026)5 filingsFeb 24, 2026Wells Fargo · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
5Huntington5Huntington says it continuously monitors model performance and may update its statistically based models as enhancements are identified. (Form 10-Q, MD&A, filed Apr 30, 2026)5 filingsApr 30, 2026Huntington · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
6Morgan Stanley5Morgan Stanley defines model risk as adverse consequences from incorrect or misused model outputs, including financial loss and reputational damage. (Form 10-Q, MD&A, filed May 5, 2026)4 filingsMay 5, 2026Morgan Stanley · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
7JPMorgan5JPMorgan says its market risk models are inherently imprecise and may be less reliable during sudden or severe market shifts. (Form 10-Q, other, filed May 1, 2026)4 filingsMay 1, 2026JPMorgan · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
8Regions4Regions' Risk Committee monitors model performance, including generative AI, among other key risks. (Form DEF 14A, proxy, filed Mar 23, 2026)4 filingsMar 23, 2026Regions · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
9Schwab4Schwab 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 ↗
10KeyBank4KeyCorp says some of its models use AI or machine learning, adding complexity such as data needs, algorithmic bias and interpretability challenges. (Form 10-K, risk factors, filed Feb 23, 2026)3 filingsFeb 23, 2026KeyBank · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
11HSBC 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 ↗
12Atlantic Union4Atlantic Union says some of its models use AI or machine learning, which carry unique complexities such as training data needs, bias potential, and interpretability… (Form 10-K, risk factors, filed Feb 26, 2026)2 filingsFeb 26, 2026Atlantic Union · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
13PNC4PNC cautions that automated AI tools depend on data quality and that humans may better detect anomalous data or results. (Form 10-K, risk factors, filed Feb 20, 2026)2 filingsFeb 20, 2026PNC · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
14Citi3Citi'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 ↗
15Zions3Zions says deposit models are updated when behavior diverges and all model changes are independently reviewed by its Model Risk Management function. (Form 10-Q, MD&A, filed May 7, 2026)3 filingsMay 7, 2026Zions · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
16Western Alliance3A Model Risk Management Committee oversees the company's Model Risk Management Framework and reports model risk to the ERMC. (Form DEF 14A, proxy, filed Apr 22, 2026)3 filingsApr 22, 2026Western Alliance · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
17Ally3Ally says responsible AI practices are built into design, approval and operational controls, with continuous testing and independent model validation. (Form DEF 14A, proxy, filed Mar 18, 2026)3 filingsMar 18, 2026Ally · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
18Amex3Amex warns that its and its partners' AI and ML use carries risks such as biased or inaccurate results and hallucinated outputs. (Form 10-K, risk factors, filed Feb 6, 2026)3 filingsFeb 6, 2026Amex · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
19Raymond James3Raymond 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)3 filingsNov 25, 2025Raymond James · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
20Eastern Bank3Eastern 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 ↗
21First Hawaiian3First Hawaiian says it closed key supervisory recommendations on model risk and data governance, strengthening regulatory credibility. (Form DEF 14A, proxy, filed Mar 12, 2026)2 filingsMar 12, 2026First Hawaiian · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
22Renasant3Renasant says it relies on third-party AI models, so it depends partly on how those third parties develop and train them. (Form 10-K, risk factors, filed Mar 2, 2026)2 filingsMar 2, 2026Renasant · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
23NBT3NBT says it uses AI across platforms, including third-party systems, and evaluates AI tools through its SDLC with model validation and risk controls. (Form 10-K, business, filed Feb 27, 2026)2 filingsFeb 27, 2026NBT · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
24Bank of Hope3Hope Bancorp's Model Risk Management Department validates models, evaluating reasonableness and sensitivity of significant judgments and assumptions. (Form 10-K, other, filed Feb 25, 2026)2 filingsFeb 25, 2026Bank of Hope · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
25Sallie Mae3SLM warns AI models could leak confidential information or infringe IP, and their opacity makes risks hard to assess and mitigate. (Form 10-K, risk factors, filed Feb 19, 2026)2 filingsFeb 19, 2026Sallie Mae · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
26Simmons Bank2Simmons says third-party AI models carry risks in how they are developed, trained and deployed, including unauthorized training data and limited visibility into… (Form 10-Q, risk factors, filed Aug 5, 2026)2 filingsAug 5, 2026Simmons Bank · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
27FNB2FNB says its AI Policy and Model Risk Management Policy target prudent AI deployment with focus on transparency, explainability and bias mitigation. (Form DEF 14A, proxy, filed Mar 25, 2026)2 filingsMar 25, 2026FNB · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
28Santander US2Santander warns AI models may be flawed, biased or trained on poor data, with errors that may not be easily detectable. (Form 10-K, risk factors, filed Mar 2, 2026)2 filingsMar 2, 2026Santander US · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
29Banc of California2Banc of California warns third-party AI systems may produce inaccurate or biased outputs or leak confidential information, and its reliance on vendors limits its… (Form 10-K, risk factors, filed Feb 27, 2026)2 filingsFeb 27, 2026Banc of California · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
30Rockland Trust2Independent Bank warns generative AI models may produce incorrect, biased, or harmful output and leak confidential information. (Form 10-K, risk factors, filed Feb 27, 2026)2 filingsFeb 27, 2026Rockland Trust · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
31First 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 ↗
32Banner Bank2Banner warns that flawed algorithms or biased data could cause compliance violations or discriminatory lending outcomes. (Form 10-K, risk factors, filed Feb 25, 2026)2 filingsFeb 25, 2026Banner Bank · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
33Northern Trust2Northern 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 ↗
34U.S. Bank2U.S. Bank says its AI and machine learning models carry complexities including data needs, algorithmic bias and explainability challenges that can reduce accuracy. (Form 10-K, risk factors, filed Feb 23, 2026)2 filingsFeb 23, 2026U.S. Bank · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
35Capital One2Capital One says it relies on quantitative models and some AI for risk management, estimates, forecasts and capital compliance. (Form 10-K, risk factors, filed Feb 19, 2026)2 filingsFeb 19, 2026Capital One · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
36SoFi2SoFi says its own AI use is limited but its systems and partners' systems increasingly rely on complex AI that may contain undetectable errors. (Form 10-K, risk factors, filed Feb 17, 2026)2 filingsFeb 17, 2026SoFi · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
37WaFd Bank2WaFd warns generative or agentic AI models may produce incorrect, biased, privacy-breaching, infringing or harmful outputs or actions. (Form 10-K, business, filed Nov 18, 2025)2 filingsNov 18, 2025WaFd Bank · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
38Axos Bank2Axos warns generative AI models may produce incorrect, biased, confidential-leaking or infringing output. (Form 10-K, risk factors, filed Aug 21, 2025)2 filingsAug 21, 2025Axos Bank · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
39BNY2BNY's risk committee reviews model risk among its significant risk exposures overseen at Board level. (Form DEF 14A, proxy, filed Mar 5, 2025)2 filingsMar 5, 2025BNY · in their words →SEC EDGAR ↗ · SEC EDGAR ↗
40BofA2BofA warns that its models have limitations, including emerging risks from AI-reliant applications. (Form 10-K, risk factors, filed Feb 25, 2025)2 filingsFeb 25, 2025BofA · in their words →SEC EDGAR ↗ · 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 the extractor classified as model risk (model validation, model error, reliance on models). Score = such quotes; ties by distinct filings, then the newest filing.

Counts: 66 of 141 profiled banks qualify; the table shows the top 40; 80 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?

BOK Financial Corporation leads with 12 filing quotes: 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). State Street is second with 9.

How many large banks discuss AI model risk in SEC filings?

66 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 the extractor classified as model risk (model validation, model error, reliance on models). 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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