AI is now a top risk the examiner will test.
Tokto gives the bank's risk and compliance officer one record that ties every AI capability, every model output, and every consumer-facing decision to a policy, a control, and a date, ready for the OCC, the FRB, the CFPB, the audit committee, and the board risk committee.
The prudential examiner adds AI to the exam scope. The CFPB opens an inquiry on the dispute-handling model. The audit committee asks the CRO for the AI risk assessment and the control evidence behind it. The risk function has a policy, a model inventory, and a RAG status — but no attributable record of how any model behaved on a consumer file.
What you get with Tokto
- Every model output scored and recorded against a consumer, an account, a policy, a control, and a model version.
- A single evidence layer that the OCC, the FRB, the CFPB, the SOC 2 auditor, and the board risk committee read against the same record.
- Policy enforced at the prompt: no model-generated dispute outcome without review, no AI marketing claim outside the formal disclosure.
- AI risk that is measured against appetite, examinable on demand, and attestable to the board.
How it works
Tokto makes AI a managed line in the risk framework rather than an emerging-risk footnote. Every consumer chatbot, every model summary, every credit-decision assist becomes a scored record at the moment of output, carrying the policy applied, the control that fired, the model version, and the disclosure language active that day. The three lines of defense work the same record.
When the prudential regulator tests AI controls, when the CFPB asks how a dispute outcome was produced, when the audit committee asks whether AI is inside risk appetite, the answer is one query against the system of record. The CRO reports AI the way credit and operational risk are reported — quantified, controlled, and evidenced.
What goes wrong without it
- AI sits in the emerging-risk column for two years. The first hard number is a CFPB consent order.
- An examiner tests AI controls and the second line cannot evidence them. A matter requiring attention is opened.
- A model produces a consumer dispute outcome with no recorded review. The control gap surfaces in an enforcement file.
- The audit committee asks if AI is within appetite. The CRO answers with a heat map, not a record.
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 Regulatory / Risk in Banking.
Book a demo