# UMB Financial: Responsible AI

Source: https://www.bankingnewsai.com/banks/umb/responsible-ai
Last updated: Oct 16, 2026

*Part of the [UMB Financial AI strategy profile](https://www.bankingnewsai.com/banks/umb).*

## How does UMB govern AI risk, and how has its disclosure changed?

UMB governs AI through its existing risk structure rather than a dedicated AI body. The 10-K for 2025, filed February 26, 2026, places third-party and emerging-technology risk, 'including emerging technology (e.g., artificial intelligence)', under a Technology, Operations, Privacy and Security (TOPS) Committee co-chaired by CISO and chief privacy officer Justin Rainey and by Uma Wilson, chief information, bank product and operations officer; Rainey reports to Shannon Johnson, chief administrative officer and, since February 2026, chief risk officer. The 2026 proxy, filed March 12, 2026, gives the board Risk Committee, chaired by Kris Robbins, oversight of emerging-technology risk including AI. Both are new. The 10-Ks for 2023 and 2024 mentioned AI only once, as added risk when technology initiatives implicate AI or automation; the 2025 proxy and the third-quarter 2025 10-Q did not mention it. The 2025 10-K extends AI to privacy law, service providers' AI, controls over outside platforms and the warning that UMB's framework may not manage AI usage effectively. UMB publishes no AI principles, model inventory or bias-testing results, and its 2026 10-Qs add nothing on AI. ([UMB Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/101382/000119312526076496/umbf-20251231.htm), [UMB Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/101382/000119312526103203/d82141ddef14a.htm), [UMB Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/101382/000095017024018456/umbf-20231231.htm), [UMB Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/101382/000095017025028420/umbf-20241231.htm), [UMB Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/101382/000119312525054504/d902757ddef14a.htm), [UMB Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/101382/000119312525257610/umbf-20250930.htm), [UMB Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/101382/000119312526194310/umbf-20260331.htm), [UMB Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/101382/000119312526325054/umbf-20260630.htm))

## Which committees and officers oversee AI risk at UMB?

| Body or officer | Role in AI risk | Source date | Sources |
| --- | --- | --- | --- |
| Technology, Operations, Privacy and Security (TOPS) Committee | Management committee overseeing third-party and emerging-technology risk, including AI; co-chaired by the CISO/CPO and the chief information, bank product and operations officer | February 26, 2026 | [UMB Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/101382/000119312526076496/umbf-20251231.htm) |
| Board Risk Committee | Ten independent directors chaired by Kris Robbins oversee the risk framework, including information security and emerging technology (including AI) | March 12, 2026 | [UMB Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/101382/000119312526103203/d82141ddef14a.htm) |
| Justin Rainey, CISO and chief privacy officer | Leads cybersecurity, business continuity, physical security, privacy and third-party risk; reports to the chief administrative and risk officer | 2025-2026 | [UMB Financial](https://blog.umb.com/inside-umb-meet-our-leaders-justin-rainey), [UMB Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/101382/000119312526076496/umbf-20251231.htm) |
| Shannon Johnson, chief administrative officer and chief risk officer | Chief risk officer since February 2026; the CISO/CPO reports into this role | February 26, 2026 | [UMB Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/101382/000119312526076496/umbf-20251231.htm) |
| Leroy Williams Jr., director | Risk Committee member; former global CIO of Ball Corporation and founder of CyberTekIQ | March 12, 2026 | [UMB Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/101382/000119312526103203/d82141ddef14a.htm) |

## How has AI appeared in UMB's SEC filings?

| Filing | What it says about AI | Filed | Sources |
| --- | --- | --- | --- |
| 10-K for 2023 | One reference: technology initiatives that 'may implicate new technologies or solutions such as those related to artificial intelligence or automation' carry additional risk | February 22, 2024 | [UMB Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/101382/000095017024018456/umbf-20231231.htm) |
| 10-K for 2024 | The same single technology-initiatives reference | February 27, 2025 | [UMB Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/101382/000095017025028420/umbf-20241231.htm) |
| 2025 proxy | No reference to artificial intelligence | March 14, 2025 | [UMB Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/101382/000119312525054504/d902757ddef14a.htm) |
| 10-Q for Q3 2025 | No reference to artificial intelligence | October 30, 2025 | [UMB Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/101382/000119312525257610/umbf-20250930.htm) |
| 10-K for 2025 | AI named under the TOPS committee remit and in risk factors on privacy and data-use law, service providers using AI, controls over outside platforms and technology initiatives | February 26, 2026 | [UMB Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/101382/000119312526076496/umbf-20251231.htm) |
| 2026 proxy | Board Risk Committee oversight of emerging technology including AI | March 12, 2026 | [UMB Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/101382/000119312526103203/d82141ddef14a.htm) |
| 10-Qs for Q1 and Q2 2026 | No reference to artificial intelligence | April 30 and July 30, 2026 | [UMB Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/101382/000119312526194310/umbf-20260331.htm), [UMB Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/101382/000119312526325054/umbf-20260630.htm) |

## What does UMB do in practice, and what is not published?

The 2025 10-K warns that solutions using AI carry uncertain legal, data and privacy risk, that AI controls must adapt to reliance on outside platforms, and that the bank's risk framework 'may not' manage AI usage effectively. ([UMB Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/101382/000119312526076496/umbf-20251231.htm))

For customers, UMB's guidance covers AI-enabled fraud: romance scammers can generate realistic photos with AI, and social engineers can use AI to manipulate voice recordings or images. ([UMB Financial](https://blog.umb.com/personal-banking-how-to-identify-romance-scams/), [UMB Financial](https://blog.umb.com/personal-banking-how-to-protect-yourself-from-social-media-scams))

UMB has not published AI principles, a model inventory, validation or bias-testing results, or how the payment-fraud AI its fraud unit tested is governed. ([UMB Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/101382/000119312526076496/umbf-20251231.htm), [American Banker](https://www.americanbanker.com/news/2025-the-most-powerful-women-to-watch-no-15-uma-wilson-umb-bank))

## What does the UMB profile record on this topic?

| Date | Move | Detail | Sources |
| --- | --- | --- | --- |
| Jul 30, 2026 | Q2 2026 10-Q has no AI language | The quarterly report contains no reference to artificial intelligence, as in the Q1 filing. | [UMB Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/101382/000119312526325054/umbf-20260630.htm) |
| Apr 30, 2026 | Q1 2026 10-Q has no AI language | The quarterly report filed the day after the call contains no reference to artificial intelligence. | [UMB Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/101382/000119312526194310/umbf-20260331.htm) |
| Mar 12, 2026 | 2026 proxy: Risk Committee oversees AI risk | The board Risk Committee, chaired by Kris Robbins, oversees the risk framework including information security and emerging technology (including AI). | [UMB Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/101382/000119312526103203/d82141ddef14a.htm) |
| Feb 26, 2026 | 2025 10-K: AI named seven times | Up from one mention a year earlier; AI now appears in risk factors on privacy law, third-party service providers, internal controls, technology initiatives and the TOPS committee remit. Shannon Johnson is listed as chief administrative officer and, since February 2026, chief risk officer. | [UMB Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/101382/000119312526076496/umbf-20251231.htm), [UMB Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/101382/000095017025028420/umbf-20241231.htm) |
| Feb 26, 2026 | 2025 10-K: AI under the TOPS committee | Emerging technology such as AI is overseen by the Technology, Operations, Privacy and Security Committee within enterprise risk; AI or automation in technology initiatives is flagged as added risk. | [UMB Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/101382/000119312526076496/umbf-20251231.htm) |
| Apr 28, 2025 | UMB profiles its CISO and chief privacy officer | Justin Rainey, with more than two decades in information security and privacy, holds the dual CISO/CPO role. | [UMB Financial](https://blog.umb.com/inside-umb-meet-our-leaders-justin-rainey) |
| Feb 27, 2025 | 2024 10-K carries one AI reference | Artificial intelligence appears once, in the risk factor on technology initiatives that may implicate AI or automation. | [UMB Financial (SEC filings)](https://www.sec.gov/Archives/edgar/data/101382/000095017025028420/umbf-20241231.htm) |

## Common questions

### Who oversees AI risk at UMB?

Management oversight sits with the Technology, Operations, Privacy and Security Committee, co-chaired by CISO and chief privacy officer Justin Rainey and chief information officer Uma Wilson. At board level, the Risk Committee chaired by Kris Robbins oversees emerging-technology risk including AI, per the 2026 proxy statement.

### When did UMB start disclosing AI risk?

UMB's 10-Ks for 2023 and 2024 mentioned AI only once, as an added risk in technology initiatives. Its 2025 proxy and third-quarter 2025 10-Q did not mention AI. The 10-K filed February 26, 2026 and the proxy filed March 12, 2026 added AI to committee remits and to several risk factors.

### Does UMB have AI principles?

No published AI principles, responsible-AI policy or model inventory were found. UMB governs AI through its enterprise risk framework, the TOPS committee and the board Risk Committee, and its 10-K warns that the framework may not manage AI usage effectively.

### What does UMB tell customers about AI fraud?

Its consumer guidance warns that romance scammers can use AI to generate realistic profile photos and that social engineers can use AI to manipulate voice recordings or images. UMB has not described AI in its own fraud monitoring beyond the proof of concept its fraud unit reported in 2025.
## Deeper on UMB

- [What is UMB's AI strategy, and what has it said about AI?](https://www.bankingnewsai.com/banks/umb/ai-strategy)
- [What technology does UMB run, and how is it organized?](https://www.bankingnewsai.com/banks/umb/technology-stack)


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