Every AI disclosure is now an SEC document.
Tokto gives the bank's General Counsel one record that ties every AI capability, every disclosure, and every model output to a date, a policy, and a reviewer, before it lands in the 10-K, the proxy, or the consent order.
The CFPB opens an inquiry on the AI feature in the consumer app. The SEC writes about the AI disclosure in the proxy. The D&O carrier asks for an attributable record of every model output that touched a consumer file. Outside counsel asks the GC the same question. There is no record.
What you get with Tokto
- Every consumer dispute, every model summary, and every disclosed AI capability tied to a record and a date.
- A complete record for the CFPB, the SEC, the OCC, the FRB, the FCA, the bureau examiner, and the D&O carrier.
- Policy applied at the prompt: no model-generated dispute outcome without review, no AI marketing claim outside the disclosure.
- Defensibility under FCRA enforcement, SEC class action, prudential examination, and 10-K disclosure scrutiny at once.
How it works
Tokto sits between the bank's AI systems and its filings. Every disclosed AI feature, from a chatbot that explains a credit denial to a model summary on a wealth dashboard, is captured as a record at the moment it produces output. The record contains the prompt, the policy applied, the model version, the human reviewer, the consumer or account it touched, and the disclosure language active at that time.
When the SEC, the CFPB, or the prudential regulator asks how the AI feature you described in your 10-K actually behaved last quarter, the answer is one query against the system of record. The General Counsel sees the same view as the CFO, the Chief Risk Officer, and the bureau examiner.
What goes wrong without it
- An AI feature ships with marketing copy that does not match the 10-K. The disclosure becomes the basis for a securities class action.
- A model produces a consumer-facing dispute outcome with no recorded human review. The CFPB asks for the file.
- Bureau-grade data flows into a third-party model with no consent record. FCRA exposure the D&O carrier did not price.
- Persistent AI errors in customer-facing summaries with no correction log. The board reads about it in the proxy.
In January 2025, the CFPB announced a $15 million civil penalty consent order against Equifax for failing to investigate consumer disputes, allowing previously deleted inaccuracies to be reinserted, and using flawed software code that produced inaccurate consumer credit scores. The order required an FCRA compliance overhaul.
See how Tokto makes enterprise AI visible, governed, and accountable for Legal & Compliance in Banking.
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