AI governance consulting for banks & lenders

Middlebrook Data & AI Governance · Regulated finance

We help regulated financial institutions govern the AI in their reporting — making the data beneath it trustworthy, explainable, and auditable. One accountable expert who has built AI systems and owned the controls that govern them — not a junior team learning your business on your dollar.

The gap we close

Banks have spent a decade building disciplined model-risk programs under SR 11-7. But the OCC's revised guidance explicitly excludes generative and agentic AI — so the copilots, assistants, and agents now touching your reporting sit outside the controls you already trust. The moment that AI touches credit, a filing, or a customer decision, the absence of governance becomes your exposure. We close exactly that gap.

Your model-risk program didn't disappear — it just doesn't reach the AI you're actually deploying.

Who we work with

• Community banks & credit unions deploying AI without a dedicated governance function.
• Regional banks & lenders — the sweet spot: real exposure, real budget, one decision-maker.
• Insurers with heavy actuarial and model use adopting GenAI in claims and underwriting.
• Fintechs & digital lenders moving fastest on AI and increasingly under CFPB / fair-lending scrutiny.

How we work — one engine, three rungs

Start small, prove value, deepen. You only step up when the last step earns it.

• Readiness assessment — a fixed-fee, expert-led review on your real data. Two to four weeks, ending in a board-ready report: maturity scored across eleven disciplines, top risks ranked, and a prioritized roadmap your board or examiner can act on.
• Remediation — a scoped build to close the gaps the assessment found: a semantic layer, lineage, access controls, output assurance.
• Fractional advisory retainer — we stay on monthly as your Fractional Head of AI Governance: the named, accountable owner you can point to when a regulator asks "who governs your AI here?"

Take the free 4-minute readiness assessment or see pricing & engagement.

Why Middlebrook

Most governance consultants understand the frameworks but have never built an agent. Most AI builders have never owned a SOX control or sat through an exam. We've done both, in regulated finance — two decades across institutions including PennyMac and Bank of America. So when we tell you where your AI-governance gap is, it isn't from a slide deck.

Frameworks we map to

SR 11-7 (model risk) · SOX / ICFR · NIST AI RMF · ISO/IEC 42001 · EU AI Act · DORA · CFPB / fair lending · DAMA-DMBOK. We don't hand you a parallel rulebook — we extend the control environment you already run.