How does USAA govern its use of AI?
USAA publishes a 'Responsible Use of Artificial Intelligence' page with four principles: fair and inclusive, secure and responsible, human oversight ('humans guide and monitor the technology') and built on trust, and it lists where AI is used, including at USAA Federal Savings Bank to automate processes, enhance member service and detect some types of fraud. Inside, chief data, analytics and AI officer Ramnik Bajaj described in May 2025 an AI council he leads, with four executive-council members, that runs use-case intake; a model risk management function that validates each solution; and ongoing monitoring in production. Use cases are scored on four value dimensions before funding. Training came first: an AI Aware course for all 38,000 employees (2024). The bank operates under a December 2024 OCC consent order requiring risk-governance, fraud and third-party programs; the order text does not mention AI. In February 2026 USAA was granted a patent on explaining machine-learning predictions in natural language, and in September 2026 it added a director whose career spanned cyber and artificial intelligence. USAA publishes no AI risk report, model inventory or bias-testing results.[1][2][3][4][5][6][7]
Data as of Oct 16, 2026 · USAA profile updated Oct 13, 2026 · 17 sources cited on this page · 140 banks profiled on this site · Markdown
What AI principles has USAA published?
From USAA's 'Responsible Use of Artificial Intelligence' page (undated, retrieved October 2026).
| Principle | What USAA says |
|---|---|
| Fair and inclusive | 'We manage our AI systems to ensure they treat members fairly.'[1] |
| Secure and responsible | Data used in AI systems is handled under USAA's Privacy Promise; systems are reviewed and monitored to work as intended and remain secure[1] |
| Human oversight | 'AI helps our employees analyze information and improve our products and services — but humans guide and monitor the technology.'[1] |
| Built on trust | Strict internal policies and industry standards so AI use aligns with USAA's core values of service, integrity and trust[1] |
How are AI systems approved and controlled at USAA?
| Control | What it is | Source date |
|---|---|---|
| AI council | Led by Ramnik Bajaj with four executive-council members; runs intake of AI use cases | May 2025[2] |
| Value scoring before funding | Every proposed use case is evaluated against four value dimensions before it is funded | May 2025[3] |
| Model risk validation and monitoring | Model risk management validates that each solution performs as expected; a third layer monitors it in production | May 2025[2] |
| Governance before training | CIO Amala Duggirala put governance and risk management first, then senior-leader and role-based training | August 2024[8] |
| Validation built into vendor projects | Google Cloud's touchless-claims engagement included a workstream to support USAA's model validation process and pass regulatory scrutiny | February 2022[9] |
| Explainability patent | US 12,548,083 B1: an explanation module turns a model's prediction, such as a recommended coverage amount, into natural language | February 2026[6] |
| OCC consent order | Requires a risk-governance framework, fraud risk management and third-party, affiliate and shared-services risk programs at the bank; no AI language; in effect as of February 2026 | December 2024[5][10] |
| Risk and board leadership | Brian Goldman named chief risk officer (May 2025); Vice Admiral Craig Clapperton, with U.S. Cyber Command and AI-era experience, joins the board (September 2026) | 2025-2026[11][7] |
What does USAA not publish about responsible AI?
USAA has no published AI risk report, model inventory, fairness or bias-testing results, or named responsible-AI officer. Its principles page lists AI uses in marketing, insurance sales, claims, underwriting and pricing, and banking, but gives no metrics.[1]
The bank is private and files no 10-K, so there is no AI risk factor of the kind listed banks publish. The OCC order is the main public governance document for USAA Federal Savings Bank, and it addresses risk governance, fraud, IT and third parties without mentioning artificial intelligence.[5][12]
What does the USAA profile record on this topic?
The rows below are the entries of the USAA Bank AI strategy profile that bear on this page, as of Oct 13, 2026; the profile holds the full record of 24 dated moves, 14 use cases and 39 sources.
| Use case | What the record shows | Status | Source |
|---|---|---|---|
| Use-case intake, governance review and AI Aware training | Each use case is evaluated for value before funding, governance analysis precedes training, and the AI Aware course reaches all employees. | In production | [3][8][4] |
| Model risk validation and ongoing monitoring of AI solutions | After AI council intake, a model risk management function validates that each solution performs as expected and a third layer monitors it in production (Bajaj, May 2025). | In production | [2] |
| OCC-mandated risk governance, fraud and third-party programmes | The December 2024 consent order requires a risk governance framework, a fraud risk management programme and third-party, affiliate and shared-services risk management; the order remained in effect in February 2026. | Rolling out | [5][10] |
| Date | Move | Detail | Source |
|---|---|---|---|
| Mar 24, 2026 | Patent granted: damage assessment from occluded aerial images | US 12,586,372 B1, assigned to USAA: a generative model trained on pairs of clear and artificially occluded aerial images learns to recognise structural damage. | [13] |
| Feb 27, 2026 | Bank returns to profit; OCC order still in effect | President Michael Moran says USAA Federal Savings Bank earned $432 million in 2025 after a $110 million loss in 2024, has about $108 billion of assets and 9.6 million members, and is still working with the OCC on remaining issues. | [10] |
| Aug 26, 2025 | Duggirala and Troy on generative AI training and use | In a Deloitte interview, CIO Amala Duggirala describes immersive training for several hundred USAA leaders; chief transformation officer Tom Troy says USAA is testing and implementing generative AI in member experience, software development, contact-centre functions and survey analysis. | [14] |
| Jun 18, 2025 | Evident's inaugural insurance AI index puts USAA third | Of 30 large insurers in North America and Europe, AXA, Allianz, USAA, Intact Financial and Manulife were the leaders on 76 metrics covering AI talent, research, use cases and responsible-AI activity. | [15][16] |
| May 14, 2025 | Brian Goldman appointed chief risk officer | Effective 27 May 2025, from Comerica, where he was chief risk officer; earlier roles at Goldman Sachs and Citibank in risk and operational risk. CEO Andrade ties the hire to enhancing the risk management culture. | [11] |
| May 13, 2025 | TechTarget interview: EagleGPT, code assist and an AI council | Bajaj describes EagleGPT for the workforce, code assist for all software engineers, a front-office AI over 20,000 documents, a Watsonx Orchestrate agent for data-access requests, and an AI council with four executive-council members; about a dozen gen-AI solutions were implemented in 2024. | [2] |
| Dec 18, 2024 | OCC issues a comprehensive consent order against USAA Federal Savings Bank | The order, which replaces the 2019 and 2022 orders, covers management, earnings, IT, consumer compliance, internal audit and suspicious-activity reporting, adds a fraud risk management article and a third-party, affiliate and shared-services article, bars new products and wider membership criteria without 90 days' notice, and imposes no penalty. USAA said progress 'has not been consistent or swift enough'. | [12][5][17] |
| Aug 14, 2024 | CIO plans AI training for 37,000 employees | Amala Duggirala describes governance and risk management first, then senior-leader training, then role-specific courses; a record-turnout hackathon moves about 55 use-case ideas into a controlled testing environment. | [8] |
Does USAA have published AI principles?
Yes. USAA's 'Responsible Use of Artificial Intelligence' page sets out four principles: fair and inclusive, secure and responsible, human oversight and built on trust. It says USAA manages AI systems to treat members fairly, reviews and monitors them to work as intended, and that humans guide and monitor the technology.
Who oversees AI risk at USAA?
Ramnik Bajaj, chief data, analytics and AI officer, leads the AI council, on which four executive-council members sit. Model risk management validates each AI solution before ongoing production monitoring. Brian Goldman has been chief risk officer since May 2025, and the board added Vice Admiral Craig Clapperton, a former U.S. Cyber Command leader, in September 2026.
Does the OCC consent order restrict USAA's AI?
The December 18, 2024 order does not mention artificial intelligence. It requires USAA Federal Savings Bank to build risk-governance, fraud risk management, IT and third-party risk programs and to give 90 days' notice before adding products or widening membership; vendor AI at the bank falls inside those programs.
How does USAA explain AI decisions to members?
USAA's principles page explains, in plain language, where AI is used in marketing, claims, underwriting and banking. Its February 2026 patent US 12,548,083 describes a system that explains machine-learning predictions such as recommended coverage amounts in natural language, though USAA has not said whether it is in production.
- Responsible Use of Artificial Intelligence (undated page, retrieved 2026-10-05)
- USAA takes an 'experiment and see' approach with AI
- How USAA is building gen AI at scale with IBM
- How GenAI Helps USAA Innovate
- Consent Order, In the Matter of USAA Federal Savings Bank, AA-ENF-2024-96
- US 12,548,083 B1: System and method for interpreting predictions from machine learning models using natural language (USAA; granted 2026-02-10)
- USAA Appoints Vice Admiral Craig Clapperton to Board of Directors
- What it really takes to train an entire workforce on gen AI
- USAA and Google Cloud: modernizing insurance operations with machine learning
- USAA Federal Savings Bank bounces back after some tough years, regulator scrutiny
- USAA Appoints Brian Goldman as Chief Risk Officer
- OCC Issues Comprehensive Cease and Desist Order Against USAA Federal Savings Bank (News Release 2024-137)
- US 12,586,372 B1: System and method for assessing structural damage in occluded aerial images (USAA; granted 2026-03-24)
- USAA CIO on Generative AI: 'Relentless Learners Will Create the Future'
- Insurers ramp up AI adoption, cautiously (Evident insurance AI index, published 18 June 2025)
- USAA hires Santander tech chief as next CIO
- OCC slaps USAA over failure to fix flaws in several areas
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