learn-ai-finance-with-phoebe / Leader session 3 of 6
Learn AI + Finance with Phoebe · Leader track · Session 3 of 6

Trust, risk & governance: how to say yes to AI without betting the firm

You do not need to code to govern AI - but you do need to know the finance-specific ways it fails, the regulations already pointing at you, and the small stack of controls that lets you move fast safely. This session gives you a governance gap-scan you can run against your own team on Monday.

🟡 Leader track Leaders: CFO · risk · controllership No code, ever 45 min
0-3 · Why this matters 3-18 · Finance-specific risks 18-33 · Regulation + the stack 33-45 · Gap-scan + Q&A
Part 0

Governance is how leaders say yes

Most finance leaders think governance is the brake. It is the opposite - it is the thing that lets you take your foot off the brake. A team with no rules either freezes out of fear or pastes confidential numbers into a free chatbot; a team with a clear, light governance stack can adopt quickly because everyone knows where the lines are. Tonight is not about writing policy from scratch. It is about knowing the seven ways AI hurts a finance function, the four regulatory regimes already watching, and the six controls that cover almost all of it - then scanning your own team against them.

Live - discussed in session Self-study - read after class ★ Questions to ask Official sources covered
★ What you walk out with today A plain-English map of the finance-specific AI risks, a leader's view of SR 11-7, the EU AI Act, MAS FEAT, and SEC AI-washing scrutiny, and a filled-in governance gap-scan: for each of the six core controls, where your team stands today and the single next move to close the gap.
Part 1 · covers Coursera Intro (risks) + AIFPA foundations

The finance-specific risks 7 min live

Every industry worries about AI errors. Finance has its own flavours, because a wrong number here flows into a filing, a credit decision, or a board pack - and someone is legally accountable for it. These are the seven that should be on your risk register, and they layer into a stack of controls you can actually manage.

5 · Policy & acceptable use the rules everyone signs up to - the top of the stack 4 · Audit trail & logging who asked what, what came back, who approved it 3 · Human oversight on every decision a licensed person reviews and owns the output 2 · Model risk management inventory the models, validate them, monitor drift 1 · Data controls & privacy no MNPI or client PII in ungoverned tools builds up from data Each layer catches what the one below misses. Skip a layer and risk leaks straight through.
🔍 Click to zoom - the governance stack: five layers, bottom-up, that together cover almost every finance AI risk
LiveFabricated figures and model risk - the two that hit a P&L3 min▶

The first family of risk is about wrong numbers reaching a decision. Two forms matter most to you.

  • Hallucinated or fabricated figures. As the builder track shows in b1, an ungrounded model invents confident, well-formatted numbers. In finance that fiction can land in a board slide, a forecast, or a filing before anyone checks it.
  • Model risk. Any model used in a decision - a forecast, a credit score, a fraud flag - can be wrong in ways that are systematic, not random. Regulators treat this as its own discipline (that is what SR 11-7 is about, Part 2).
  • Over-reliance. The quieter danger. When the output looks polished, people stop checking. A team that trusts the draft blindly has re-created the fabrication risk with extra steps.
Real world

The confident forecast nobody questioned. A planning team let an AI assistant generate a driver-based forecast and, because it read cleanly, pushed it to the CFO with light review. A sign flip in one driver had inverted a segment's trajectory. It survived two meetings before a controller re-derived the math by hand. The fix was never a better model - it was a mandatory human check on any number that leaves the team.

★ Questions to ask your team Which numbers produced with AI help reached a decision last quarter without a human re-deriving them? Where would a fabricated figure do the most damage before we would catch it?
LiveExplainability, data leakage, and bias - the ones that draw regulators3 min▶

The second family is about defensibility and fairness - and it is where the law is most explicit.

  • Explainability. The leader's version of this question is blunt: can you defend this number to an auditor or a regulator? "The AI produced it" is not an answer. If you cannot trace how an output was reached, you cannot stand behind it.
  • Data leakage. Pasting real financials, MNPI, or client PII into an ungoverned tool can breach securities law, PDPA/GDPR, and confidentiality obligations at once. This is rail one, and it is the bottom layer of the stack for a reason.
  • Bias in credit and fraud. A model that scores creditworthiness or flags fraud can encode discrimination against protected groups - which is exactly why the EU AI Act treats credit scoring as high-risk (Part 2).
★ Questions to ask your team If our regulator asked us to explain one AI-assisted number, could we? Do we have a written line about what data may never enter a consumer tool - and does anyone check?
Self-studyAI-washing - the risk that points outward2 min read▶

Every risk above is about AI harming your own numbers. AI-washing is the mirror image: overstating what your AI does, to clients, investors, or the market. The SEC has already penalised firms for it. For a finance leader this shows up in marketing copy, investor decks, and product claims - and the rule is simple: be exactly as honest externally about your AI as you are internally. If your team would not say it in a control review, do not put it in a brochure.

★ Questions to ask your team Does any client-facing or investor-facing material claim an AI capability we could not demonstrate in a room? Who signs off on AI claims before they go out?
Part 2 · covers SR 11-7, EU AI Act, MAS FEAT, SEC guidance

The regulatory map 5 min live

You do not need to read the statutes - your compliance and legal teams do. But you do need the leader's-eye view, so you can ask the right questions and recognise when a use case has crossed into regulated territory. Four regimes shape almost every finance AI conversation today.

LiveWhat each regime actually demands of finance3 min▶
RegimeWhat it demands of a finance function
US Fed SR 11-7 - model risk managementKeep an inventory of models in use, validate them independently, and monitor them over time. Treats any model driving decisions as a governed asset, not a spreadsheet.
EU AI Act - risk tiersClassifies AI used for credit scoring as high-risk, triggering extra duties: documentation, human oversight, data quality, and transparency. Higher risk = more obligations.
Singapore MAS FEAT / VeritasFour principles for AI in financial services: Fairness, Ethics, Accountability, Transparency. Principles-based - asks you to show you took them seriously.
SEC / FINRA - marketing + AI-washingScrutinises overstated AI claims in marketing and disclosures. Say only what you can demonstrate; accountability for the claim stays with the firm.
These move fast - treat dates as perishable EU AI Act timelines phase in over several years, and MAS and SEC guidance updates regularly. Use this table for the shape of the obligations, and have your compliance team re-verify specifics before any decision rests on them.
Self-studyThe pattern underneath all four2 min read▶

Read together, the four regimes are asking for the same handful of things in different accents:

  • Know your models. An inventory - what AI is in use, for what, owned by whom (SR 11-7).
  • Match effort to risk. A credit model gets more scrutiny than a memo drafter (EU AI Act tiers).
  • Keep a human accountable. Someone owns the decision, always (FEAT accountability, SR 11-7).
  • Be able to explain and evidence it. Documentation, audit trail, honest external claims (FEAT transparency, SEC).
Four regimes, different accents - the same four demands US Fed SR 11-7 model risk management EU AI Act risk tiers, credit = high-risk MAS FEAT / Veritas principles for AI in finance SEC / FINRA marketing + AI-washing Know your models an inventory: what is in use, whose Match effort to risk credit models get the most scrutiny Keep a human accountable someone owns the decision, always Explain and evidence it docs, audit trail, honest claims Deliver these four and you are most of the way to defensible under any of the regimes.
🔍 Click to zoom - four regimes ask for the same four things: know your models, match effort to risk, keep a human accountable, explain and evidence it

If your governance stack (Part 3) delivers those four, you are most of the way to defensible under any of these regimes - which is exactly why the stack is worth more than memorising any single rule.

Part 3 · the leader mirror of builder b10

The governance stack you actually need 5 min live

Here is the good news: you do not need a governance function the size of a bank's to be responsible. Six controls cover the vast majority of finance AI risk, and each one is a management decision, not a technical build. This is the leader's mirror of what the builder track constructs in b10.

LiveThe six controls, in the order to build them3 min▶
  • Acceptable-use policy. One page: what AI may and may not be used for, which data may never go in, who to ask when unsure. The thing everyone signs up to.
  • Tool tiers. Decide which tools are cleared for which data - consumer (public/synthetic only), enterprise (real financials, contractually no training), local (most sensitive). The privacy line made concrete.
  • Human-in-the-loop on all decisions. Every workflow that produces a number, decision, or external output has a named human who reviews and owns it. Rail two as an org rule.
  • Logging and audit trail. Keep a record of significant AI-assisted work: the ask, the output, the approver. This is what lets you answer the auditor's question.
  • Model inventory. A living list of AI tools and models in use, what they do, and who owns each. You cannot govern what you have not written down.
  • Review cadence + incident plan. A regular check that the above is being followed, and a pre-agreed plan for when something goes wrong - who is told, what stops, how you remediate.
Real world

Six controls in an afternoon. A mid-size finance team stood up all six in a single workshop: a one-page policy, three tool tiers, a sign-off rule, a shared log, a model list in a spreadsheet, and a quarterly review on the calendar. None of it was technical. It was enough to move from "quietly nervous" to "openly adopting" - and enough to satisfy their first internal audit.

★ Questions to ask your team Of these six, which do we already have in some form? Which single one, if we added it this quarter, would reduce the most risk? Who would own each?
Self-studyRight-sizing the stack to your risk2 min read▶

Not every team needs the heaviest version of every control. Match the weight to the risk:

  • Drafting and summarising (commentary, memos) → policy + tool tiers + a light human edit is enough.
  • Analysis and forecasting → add human sign-off on any number that leaves the team, plus logging.
  • Credit, fraud, or anything about a person's money → the full stack, plus model inventory and validation, because this is where SR 11-7 and the EU AI Act bite hardest.

The art of governance is not maximum control everywhere - it is proportionate control, heaviest where a mistake hurts a person or breaks a law.

Touches credit, fraud, or money? Is it analysis or forecasting? yes no yes no Full stack + validation SR 11-7 + EU AI Act bite hardest Add sign-off + logging on any number that leaves Policy + tiers + light edit is enough Proportionate control, not maximum control everywhere - heaviest where a mistake hurts a person or breaks a law.
🔍 Click to zoom - match the control to the risk, not the same rules everywhere
Exercise

Run a governance gap-scan on your team ◐ 20-30 min

No code, no tools - a table and an honest conversation. Score your team against the six controls, then turn the two biggest gaps into named owners and dates. This is the artifact you take back to your risk or exec meeting.

★ Questions to ask any AI vendor Do you train your models on our inputs, and can we contractually opt out? How long is our data retained, and where? For any decision-support feature, how do we explain an output to an auditor? What audit logs do we get, and can we export them?
Source material

Official sources covered

This session teaches the leader's working view of the finance-AI regulatory canon. The statutes, official guidance, and any binding interpretation stay with the regulators and your own legal and compliance teams - said honestly. This session covers:

✓US Fed SR 11-7 - Guidance on Model Risk ManagementParts 1-3 · inventory, validation, monitoring as a leader concept
✓EU AI Act - risk-tier classificationPart 2 · credit scoring as high-risk and what that triggers
✓Singapore MAS FEAT / Veritas principlesPart 2 · Fairness, Ethics, Accountability, Transparency
◐SEC / FINRA - marketing rule & AI-washing guidancePart 1 · outward-facing honesty; re-verify as guidance evolves
Check yourself

Three questions before you go 🎯 ◐ 90 seconds

1 · At its core, what is US Fed SR 11-7 about?

SR 11-7 treats any model driving decisions as a governed asset: know what models you run, validate them independently, and watch them for drift. It is the backbone of the model-risk layer in your stack.

2 · Why does the EU AI Act single out credit scoring for extra duties?

The Act scales obligations to risk. Credit scoring affects a person's access to money, so it lands in the high-risk tier, triggering documentation, human oversight, data-quality, and transparency duties.

3 · Your team used AI to help produce a number in a filing. Why does an audit trail matter?

"The AI produced it" is not a defence. An audit trail - the ask, the output, the human approver - is what lets you explain and stand behind an AI-assisted number when someone asks how you got there.

Leader session 3 cheat sheet · pin this

Governance = permission to go fastclear lines let a team adopt quickly instead of freezing or going rogue. It is the accelerator, not the brake.
Finance-specific risksfabricated figures, model risk, weak explainability, data leakage, bias in credit/fraud, over-reliance, AI-washing.
SR 11-7model risk management: inventory your models, validate them, monitor them. Any decision model is a governed asset.
EU AI Actcredit scoring = high-risk → extra documentation, human oversight, data-quality and transparency duties.
MAS FEATFairness, Ethics, Accountability, Transparency - the principles test for AI in financial services.
AI-washingSEC scrutinises overstated AI claims. Be exactly as honest externally as you are in a control review.
The six controlspolicy · tool tiers · human-in-loop · logging/audit trail · model inventory · review cadence + incident plan.
Next sessiona4 - the AI-ready finance team: the skills to build, the roles that shift, and how to lead the change.