SR 11-7 Just Wrote Itself Out of the GenAI Conversation
The April 17, 2026 interagency MRM rewrite formally excludes generative and agentic AI from scope. That's not a retreat — it's an RFI window.
AI governance for financial services
I work on the gap between Model Risk Management frameworks like SR 11-7 and SS1/23 and the actual mechanics of generative and agentic AI systems in production. The interesting questions sit where regulatory expectations meet engineering controls — and most firms are trying to bridge that gap with policy documents alone.
I'm Chief Information Security Officer at Tetrate and a contributor to the FINOS AI Governance Framework, where I received the Newcomer Award at OSFF NYC 2025. I take a small number of fractional advisory engagements with banks, insurers and FS infrastructure firms working through AI governance implementation — and I write about the work here.
The April 17, 2026 interagency MRM rewrite formally excludes generative and agentic AI from scope. That's not a retreat — it's an RFI window.
Two products that never shipped, one pattern that killed them both, and the tool I eventually built to fix it
Coming to the same answer twice is kind of cool
How to use FINOS CALM architecture-as-code to implement re-usable deployment patterns for AI in financial services
Multiple three hour workshops where I guided attendees through the process of brainstorming and developing an AI reference architecture for financial services institutions.
How to build executable governance, transforming abstract policies into resilient, auditable code.
Tetrate developed a modern visualization tool for FINOS CALM to address the critical gap between AI governance frameworks and their practical implementation.
A practical guide for Chief Information Security Officers on implementing controls for governing distributed AI tools across enterprise SaaS applications.
Examining how agentic AI systems depending on third-party Model Context Protocol (MCP) services face unique security challenges and proposing infrastructure-level governance solutions.