For CCOs · CROs · Chief Model Risk Officers
Three regulators are asking. Your file answers all three or it answers none.
The state AG, the EU AI Act, and your OCC examiner each open a distinct exposure surface in 2026. The compliance evidence and the credentialed talent are the same artifacts. The Compact is the only program built to produce that evidence across all three concurrently.
I · The Exposure
Three exposure surfaces. One artifact pack.
The federal ECOA disparate-impact theory ended on April 22, 2026. The three regulators below did not. The Compact prepares the workforce for all three concurrently — same Sprint artifact pack, three defensible reads.
Surface 1
$2.5M
+ governance program
State Attorneys General
Mass AG v. Earnest, Jul 10, 2025. Brought under Massachusetts Chapter 93A consumer-protection law, not federal ECOA. Unaffected by the April 22, 2026 CFPB rule. Remediation required a "written corporate governance system of fair lending testing, internal controls, and risk assessments."
NY AG opened algorithmic-pricing investigation Jan 8, 2026 (Instacart). Texas TRAIGA effective Jan 1, 2026, AG-exclusive enforcement, $10K–$200K per violation, 60-day cure. Colorado SB21-169 first attestations due Jul 1, 2026.
Surface 2
€35M
or 7% global revenue
EU AI Act Annex III §5(b)
Enforceable August 2, 2026. Credit-scoring AI is explicitly high-risk under Annex III §5(b). Conformity assessment, EU database registration, quality management system, technical documentation, human oversight, and accuracy/robustness/cybersecurity standards required.
Affects any US institution with material EU consumer exposure. The proposed Digital Omnibus could push to December 2, 2027 but is not yet law — Aug 2, 2026 is the binding date.
Surface 3
17 MRAs
AI-related since 2020
OCC Examiner MRA Pattern
The OCC has issued 17 AI-related Matters Requiring Attention since 2020 and conducted an AI-focused review of seven large banks (2019–2023). MRAs are non-public — they do not appear in press releases.
They appear in your next examination cycle's open-items list, and they follow your CCO to her next role. The 2026 tri-agency MRM rewrite excluded generative and agentic AI from scope — the formal guidance is silent, but the supervisory expectation is not.
67% of your headcount touches the regulator-visible workflow daily. Every AI-governance credential on the market trains the other 33%. The Compact trains the 67%.
Built for Henrietta First
The Compact begins at the CCO\'s desk.
Henrietta is the Chief Compliance Officer at a $40B–$60B super-regional bank. JD. Twenty-two years in compliance. Two CFPB exams. One PA Senate testimony. Her 30-day arc with The Compact produces a four-piece Board-Ready Package she can walk to the Audit Committee Chair before next quarter\'s board cycle.
Workforce Coverage Diagnostic
One page. Headcount × 8 universal modules × 5 role-families. Headline number: 4.8% today / 80% by Day 90.
Board Attestation Draft
Two pages. Citation-grounded. "Documented Today / Committed by Day 90" split. Pressure-tested by Sentinel playing three Audit Committee members.
Phase-1 Cohort Roster
One page. 15 named seats + 1 faculty-observer seat. Twelve-week commitment. Two-sentence rationale per seat.
Regulator-Readiness Pack
Six pages. The 24-hour-response binder. Recoverable within a day of an OCC or state-AG inquiry. Filed to evidence ledger with content-hash.
"Welcome, Henrietta. Day One for you is about the institution, not the credential. Your 30 days produce a board-ready attestation of your bank\'s Witness-Posture coverage and a plan for the Phase-1 cohort that will move your senior team to Reader and Steward."
Sentinel · Architect voice — adversarial peer, not warm-Socratic. Henrietta will not be patronized by her AI coach.
II · The Sprint
Board-ready by Day 30.
The Lending Risk Readiness Sprint is the entry. The Witness Onramp is the bundle that turns the pilot into Compact membership.
Sprint · Standalone
$25K
30 days · Compliance evidence delivered · Founder-led
- Regulatory Threat Simulator run against your lending profile
- 6-stage cascade analysis · cryptographically signed PDF
- Capability Graph Diagnostic for the bank
- Board-ready Readiness Report · 12–18 pages
- 30-minute board-deck walkthrough · founder-led
- Audit-grade hash-chain of every deliverable
Sprint + Witness Onramp
$35K
30 days · Same deliverables + 6 Compact membership seats
- Everything in the standalone Sprint
- 6 seats in the Universal Layer · L0 by Day 30
- Each seat earns the Witness Posture credential
- Seats from any role family (typically CCO + MRO + 4 frontline)
- AGRS L0 credentials filed in your evidence ledger
- Cohort priority for Phase-1 enrollment (12-week, AGRS L2)
III · What You Walk Out With
Six deliverables. All board-ready.
Cascade PDF · cryptographically signed
A six-stage cascade analysis of one regulator-pressure scenario against your bank's actual AI lending posture. Each stage is hash-chained. The PDF is the artifact your CMRO files.
Readiness Report · board-grade
12–18 pages. Federal-Reserve-style typography. One-page summary, four-page narrative, eight-page evidence appendix. Designed to fit alongside your existing board packets.
Capability Graph Diagnostic
Your bank's AI governance capabilities mapped against the AGRS six-dimension rubric. Shows where you stand today and what's required to move each dimension up one band.
Six AGRS L0 credentials
Six members of your team earn the Witness Posture. Credentials filed in your evidence ledger. Board attestation language supplied alongside.
Walkthrough · 30 min · founder-led
A live session with your CMRO, CCO, and optionally a board observer. The founder presents the Readiness Report against your bank's risk posture.
Phase-1 cohort priority
Sprint customers receive priority enrollment for the next Phase-1 cohort — the 12-week path to AGRS L2 — at preferred pricing. Up to four seats reserved.
IV · The Math
Compare the Sprint to what you\'d otherwise spend.
Annualized cost of the gap · $25B mid-market commercial bank · conservative figures
CFPB-Circular-2023-03 enforcement action (Earnest pattern)
$2,500,000
External counsel on an MRA response lacking documented frontline evidence
$~1,440,000
Big 4 advisory engagement for AI governance gap-fill (90 days)
$~800,000
Internal time cost of unprepared examination response
$~280,000
The Sprint + Onramp bundle
$25K–$35K
Single-event coverage ratio · Sprint to enforcement · ~100×
V · Common Questions
What CCOs ask first.
AIGP is a knowledge-based exam — Kirkpatrick L2 — that measures vocabulary, not behavior. The Compact's AGRS is evidence-portfolio-based (Kirkpatrick L3/L4). We don't compete with AIGP. We slot above it. ISO/IEC 42001 lives at the management-system level; AGRS supplies the individual-evidence layer underneath.
The Sprint is delivered by the Compact's founder, with Sentinel (the AI co-pilot built on Claude) doing the bulk of the analysis work in your evidence environment. There is no outsourced consulting layer. This keeps the price defensible at $25K and the analysis depth high.
The Sprint operates against your AI inventory at a level you authorize — typically a high-level model registry, one selected workflow's policy file, and your bank's adverse-action template. Customer data does not leave your environment.
The Sprint plus 6-seat Witness Onramp is the wedge. After completion, the Universal Layer rollout covers 100% of your workforce at AGRS L0 within 90 days at volume pricing — typically $50–150/seat/year depending on org size.
AGRS is positioned as evidence-portfolio-based, not certification-required. The Sprint deliverables cite the regulator's own letters and rules (SR 11-7, OCC 2026-13, CFPB Circular 2023-03) in the institution's voice. The credential is a private artifact that backs the public attestation.
The first three pilots set the methodology
If your bank, credit union, or insurance company would be one of them, the conversation is one hour. We bring the cascade simulation; you bring the wedge scenario you care about.
No procurement vendor onboarding required for the Sprint · Standard MNDA on the call