AI Governance Practice
AI Governance Consulting for Financial Institutions, Built for the Regulatory Moment We’re In.
Formal AI regulation for financial services is coming. What regulators are examining for right now – governance frameworks, model documentation, oversight protocols, and vendor oversight – is already well-defined, even where specific rules aren’t. CRC Oyster’s AI governance practice helps financial institutions build programs that satisfy current expectations and position them ahead of what’s next.
There Isn’t a Single AI Regulation Yet. There Are Dozens of Existing Regulations That Already Apply.
The SEC, FINRA, and other regulators have made clear that existing frameworks apply fully to AI-driven activities, regardless of whether those frameworks were designed with AI in mind. An AI tool generating investment recommendations is subject to the same fiduciary and Reg BI standards as a human advisor. An algorithm producing marketing content is subject to the Marketing Rule. An AI surveillance system must satisfy FINRA’s supervision requirements.
What is genuinely new is the operational challenge of building compliance programs around technology that operates at a scale and opacity that traditional supervisory models weren’t designed for. That’s where CRC Oyster’s AI governance practice is focused.
Our AI Governance Framework
A defined methodology, not a generic assessment. Four phases that produce a complete, documented, and regulatorily defensible AI governance program.
Phase 1
AI Inventory & Risk Assessment
Identification and documentation of all AI tools deployed across the firm: investment decision-making, client communications, surveillance, and operational workflows. Classification by use case, risk level, and applicable regulatory framework. Gap assessment against current regulatory expectations with risk-rated findings and prioritized remediation recommendations.
Phase 2
Governance Framework Design
A structured AI governance framework tailored to the firm’s specific deployments covering: AI governance policy, model documentation standards, pre-deployment approval process, human oversight requirements calibrated to each use case’s risk level, vendor oversight framework for third-party AI tools, and incident response procedures for AI failures and unexpected outputs.
Phase 3
Implementation & Documentation
Policy drafting and adoption, model documentation for all identified deployments, supervisory procedure updates, disclosure review across Form ADV and client-facing materials, training for compliance and business personnel, and vendor due diligence questionnaire development for AI tool providers.
Phase 4
Ongoing Monitoring & Regulatory Change Management
Regulatory monitoring across SEC, FINRA, CFTC, and state frameworks with proactive impact assessment. Periodic AI program reviews as new tools are deployed. Model performance monitoring for drift and degradation. New tool pre-deployment review. Examination readiness documentation and staff preparation.
Who We Serve
- Firms actively deploying AI – broker-dealers, RIAs, and fund managers using AI in investment decisions, client communications, surveillance, or operations who need governance frameworks built around specific deployments.
- Firms evaluating AI adoption – institutions that want governance infrastructure in place before deployment rather than retrofitted after.
- Firms building AI products – technology companies developing AI-native products for financial services who need to understand the regulatory environment their customers operate in.
- Firms with examination findings – institutions where regulators have identified AI governance gaps requiring credible, complete remediation.
What’s Coming and Why Building Now Is the Right Move.
The SEC has identified AI governance as an active examination priority. FINRA has published supervision guidance. The CFTC has issued requests for information on AI in derivatives markets. State-level regulation is developing. Firms with rigorous, documented AI governance programs already in place will be best positioned when formal requirements crystallize. CRC Oyster builds those programs.
Frequently Asked Questions
Your existing policies need to explicitly address how AI tools are used, overseen, and documented. Many firms’ current policies are silent on AI entirely, which creates examination exposure. CRC Oyster assesses your program and builds in the coverage it needs.
No. A regulated firm cannot outsource its compliance obligations to a vendor. If a third-party AI tool generates recommendations, produces communications, or processes client data, the firm is responsible for ensuring those activities satisfy applicable requirements.
It’s the right time. Building governance infrastructure before deployment is dramatically more efficient than retrofitting it after.