Eliminating Frontier Model Risk
SmarterFI Technical Architecture BriefHow the SmarterFI AIOS keeps generative AI inside a governed, isolated and examinable control path. Written for bank and credit union technology buyers, risk committees, compliance and internal audit: each control, the evidence behind it, and a crosswalk to the revised interagency model risk guidance, the FFIEC IT Examination Handbook, GLBA and third-party risk management expectations. It closes with a pre-approval checklist and the questions risk committees ask.
What it commits to§
- Identifiers masked before any model call
- No number from a language model
- A person decides every consequential action
- Append-only, examiner-ready audit log
Contents
- Executive Summary
- Frontier Model Risk, Defined
- Architecture Overview
- Guardrails: The Governed Path of Every Model Call
- Data Isolation, Residency and Data Minimization
- Audit Logging and Examiner Evidence
- Model Governance Mapped to Model Risk Guidance
- Regulatory, Third-Party and Assurance Mapping
- Aligned with 2026 Regulatory Frameworks
- Risk Committee Checklist and FAQ
Cite as
Donahue, J. (2026). Eliminating Frontier Model Risk: SmarterFI Technical Architecture Brief. SmarterFI.ai. Version 1.1. https://doi.org/10.5281/zenodo.23884799. CC BY 4.0
- This version
- https://doi.org/10.5281/zenodo.23915962
- All versions
- https://doi.org/10.5281/zenodo.23884799
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