For banks from $500 million to $10 billion in assets

ARCHITECT™ AI Governance Assessment for Community Banks

An expert-led AI governance diagnostic: a board-ready view of where your AI governance stands, and what to fix first.

The 2026 model risk guidance raised its threshold to $30 billion and left generative AI out of scope. Your examiners, your board and any future acquirer have not stopped asking how your bank governs the AI it already uses.

Why this matters now

No federal rule covers it.

The April 2026 interagency guidance (SR 26-2 / OCC Bulletin 2026-13) is now written for institutions above $30 billion and excludes generative and agentic AI: the category most community banks actually use.

The exam still does.

In September 2026, state supervisors gave their examiners an AI supervisory framework that reaches generative and agentic AI directly. If you hold a state charter, expect requests for your AI policy, an inventory of AI uses, risk assessments and vendor documentation.

One tool is enough.

In May 2026 a Pennsylvania community bank filed a material cybersecurity 8-K after an employee used an unauthorized AI tool on customer data. Size was no protection.

What the diagnostic gives your board

A board-ready view of where you stand

A maturity rating from Reactive to Scrutiny-Ready across all six ARCHITECT™ pillars, showing where your governance holds and where it is exposed.

An expert reading of the results

A 30-minute review with Brendan Walsh on what your results mean for your next exam, your vendor relationships and your board.

A prioritized plan

Written Recommended Next Steps, sized to a community bank: what to fix first, what can wait, and what your examiners are most likely to ask about.

What the Assessment covers

The same six-pillar ARCHITECT™ discipline applied to larger institutions, scaled to a community bank:

- Accountability

- Risk Integration

- Capital Exposure

- Horizon Scanning

- Information & Reporting

- Transparency

Proportionate by design: no regional-bank infrastructure assumed.

How it works

1. Complete the diagnostic questionnaire. A structured online questionnaire across the six ARCHITECT™ pillars.

2. See where you stand. An immediate rating from Reactive to Scrutiny-Ready, pillar by pillar.

3. Review the results with Brendan. A 30-minute consultation on what the results mean for your next exam, your board and your vendors.

4. Get your Recommended Next Steps.

A prioritized, proportionate plan your board can adopt.

Talk First

A 15-minute call to check fit, timing and scope. No obligation.

Need an invoice or purchase order? Contact us and we will arrange it.

Start Now

An expert-led diagnostic for a fixed fee of $9,500: your rating across all six pillars, a 30-minute results review, and written Recommended Next Steps.

Your fee is credited in full against an advisory retainer signed within 60 days of purchase.

READ THE ANALYSIS

No Rule Applies. The Exam Still Does.

Why the 2026 model risk guidance leaves small and community banks’ AI entirely their own problem.

Read the article →

30+ Years Executive Leadership | Former EVP, American Express ($10B P&L) | Harvard Master's in Sustainability | GARP SCR & AI Risk Certified

If your examiner asked tomorrow who owns AI at your bank and what it is running, could you show the evidence?

Fixed fee: $9,500. Your fee is credited in full against an advisory retainer signed within 60 days of purchase.

Copyright 2026. Walsh Sustainability Risk Advisory. All rights reserved.