10
Glossary and sources
6 min read · Chapter 10 of 10
Words that mean something else here
| Term | What you'd assume | What it means here |
|---|---|---|
| Model | The weights behind an API | In US bank guidance, a complex quantitative method based on statistical, economic or financial theory, with generative AI excluded; in Canada, AI and judgment tools included. Ask "under which definition?" |
| Validation | A held-out test set | In banks, an independent review of conceptual soundness, outcomes and ongoing monitoring |
| Effective challenge | Someone reviewed it | Critical review by experts with the independence and authority to force a change |
| Provider | The model lab | In the EU, whoever places a system on the market under its name, which can be a bank that built it or a deployer that rebranded one |
| Deployer | Whoever ships the code | In the EU, the professional user of a system; in Colorado and Connecticut, whoever uses it for consequential decisions |
| Agent | Software that calls tools | In Workday and California's rules, a vendor acting for an employer, and liable as one |
| Bias audit | Any fairness test | In New York City, a specific impact-ratio calculation by an independent auditor |
| Disparate impact | Unfair results | A legal theory still in the anti-discrimination statutes and many state laws, removed from Reg B and deprioritized federally |
| Human in the loop | A person clicks approve | In EU law, a competent, trained person with authority to override; token review doesn't count |
| Certified | Safe | ISO 42001 certifies a management system; SOC 2 is an attestation report; STAR for AI Level 1 is a self-assessment |
| Conformity assessment | An outside audit | For most high-risk uses, the provider's own internal check |
What surprised me
Placeholders in your voice, drafted from the research and the earlier guides. Rewrite each with your own moment.
The definition. In identity and trust a customer was a customer. Here the same AI assistant is a "model" to a Canadian bank supervisor, isn't one to a US bank supervisor, and is an "AI system" in the EU.
The retreat. In payments the rules only seemed to pile up. Here US agencies withdrew guidance in 2025 and 2026, and the liability moved to states, class actions and customers' contracts.
The certificate. In cloud security a SOC 2 report answered most of a buyer's questions. Here a lab's ISO certificate covers its own management system, and its customers get none of it by association.
The vendor in court. In AI coding agents the vendor's terms put the risk on the user. Here a court let job applicants pursue the HR software vendor directly, alongside the employers that used it.
Sources
Undated entries were read on October 9, 2026; "search result" means seen only as a search snippet or summary. Company figures are self-reported unless they come from a filing or a regulator. Analyst placements are as reported by the vendors, and vendor surveys cover the vendor's own respondents.
US bank regulators
- Federal Reserve, SR 26-2 cover letter and Supervisory Guidance on Model Risk Management (Apr 2026); OCC, Bulletin 2026-13 (Apr 2026)
- Law-firm summaries of SR 26-2: Orrick, Sullivan & Cromwell, Davis Polk (Apr 2026); Risk.net, do banks still need to validate GenAI models? (May 2026)
Canada and the UK
- OSFI, Guideline E-23 and backgrounder (Sep 2025); Blakes, final E-23 (search result)
- Bank of England, PRA SS1/23; Bank of England and FCA, AI in UK financial services 2024 (Nov 2024)
- UK automated decisions: SI 2026/82; Inside Privacy, ICO draft guidance (2026, search result); Parliament of Canada, Bill C-36
EU AI Act
- AI Act text: Article 17, Article 26, Article 27, Article 43, Article 73, Article 99
- Digital Omnibus: Cooley, deadlines delayed (2026); Stephenson Harwood, ten key takeaways (Jul 2026); ACT | The App Association, the omnibus for startups and SMEs (Aug 2026)
- Guidance and enforcement: Gowling WLG, draft high-risk guidelines (2026, search result); European Commission, code on AI-generated content (Jun 2026, search result); Digital Applied, who enforces (2026, vendor blog, search result)
US federal agencies and preemption
- CFPB, Regulation B final rule; Husch Blackwell, Reg B overhaul (2026, search result)
- EEOC, iTutorGroup (search result); Epstein Becker Green, EEOC and disparate impact (search result)
- FTC, Rite Aid (Dec 2023)
- HHS, Federal Register notice on Section 1557 (Jun 2026); Radiology Business, enforcement from May 1 (search result)
- Preemption: executive order of December 11, 2025 (search result); The Daily Signal, three-year bill (Jun 2026, search result)
US states and cities
- New York City: DCWP automated employment decision tools; DLA Piper, the comptroller's audit (Jan 2026, search result)
- Illinois: Seyfarth, rules withdrawn (2026, search result)
- California: McDermott, FEHA rules (2025, search result); Hunton, CPPA regulations (Sep 2025, search result)
- Colorado: Future of Privacy Forum, comparison of the final revisions (May 2026); Proskauer, AI law on ice and Jenner, DOJ joins xAI (2026, search result); Faegre Drinker, insurance rules expanded (Sep 2025, search result)
- Connecticut: Proskauer, new AI law (Jun 2026, search result)
- Insurance: Quarles, NAIC bulletin adoption (search result); vendor count from Openlayer (search result); NY DFS, Circular Letter No. 7 (Jul 2024)
Courts and settlements
- Mobley v. Workday: Duane Morris, June 2026 ruling (Jun 2026); Gunderson, spring 2026 update
- Health insurers: Georgetown litigation tracker, Cigna scheduling order and Humana amended answer (Aug 2026); AFS Law, UnitedHealth discovery (2026, search result)
- SafeRent: Cohen Milstein and Bloomberg Government (search result); Eightfold: Workforce Bulletin (2026, search result)
- Earnest: DLA Piper, biased underwriting models (search result); Pieces Technologies: Orrick (Sep 2024, search result)
- Italy's data protection authority: Reuters via Freevacy and EDPB on Replika (search result)
Standards and certification
- NIST, AI Risk Management Framework and ISO/IEC 23894 crosswalk (search result); ISO, the ISO Survey (search result)
- Certificates: AWS, ISO 42001, first surveillance audit and FAQ; Anthropic, ISO 42001 (Jan 2025); Help Net Security, Microsoft 365 Copilot recertification (May 2026); Google Cloud, ISO 42001; IBM, Granite ISO 42001; Snowflake certificate; KPMG, International (Dec 2025); Vanta, framework launch (Mar 2024) (search results unless dated)
- Certification bodies: Schellman, first ANAB-accredited body; BSI, UKAS and RvA accreditation (Nov 2025); consultancies' cost ranges from CertPro and Elevate (2026) (search results)
Surveys and research
- Deloitte, 2025 EMEA Model Risk Management Survey (fieldwork Jul-Sep 2025)
- IBM, Cost of a Data Breach 2025 (Jul 2025, search result)
- Vendor surveys: OneTrust, 2026 AI-Ready Governance Report (Sep 2026); Schellman, AI research report (Jul 2026); SecurityPal, what buyers ask (2026)
- Conference Board, AI risk disclosure in the S&P 500 (Apr 2026); CSO Online, IANS and Artico on security budgets (Sep 2026)
- IAPP, AI Governance Profession Report (Apr 2025); Chen, Zaharia and Zou, How is ChatGPT's behavior changing over time? (2023, search result); Promise Legal, SIG questionnaire sizes (search result)
Market, analysts and companies
- Analysts: Gartner, AI governance platforms forecast (Feb 2026, search result) and repost (Mar 2026); Forrester, AI governance software spend (search result)
- Placements as reported by vendors: OneTrust, Magic Quadrant chart description (Jun 2026); Holistic AI, Challenger; Credo AI, Forrester Leader (Aug 2025); SAS, Chartis model risk (Jan 2025) and AI governance (2026) (search results)
- IBM: watsonx.governance pricing, AWS Marketplace listing, Q2 2026 8-K exhibit (search result)
- ServiceNow: AI Control Tower expansion (May 2026); CIO.com, Control Tower spend (search result); Calcalist, Traceloop (Mar 2026, search result)
- Microsoft, Purview compliance templates; AWS, Bedrock pricing and promotional credit terms (Sep 2026); Google, Model Armor (search result)
- Specialists: BNN Bloomberg, Credo AI valuation (Jul 2024); Credo AI, AWS Marketplace listing; SiliconANGLE, Airia (Sep 2025); Monitaur Series A (May 2024); Retail Banker International, ValidMind seed (2024) (search results)
- GRC and compliance automation: Hg, AuditBoard (May 2024); Help Net Security, AuditBoard and FairNow (Oct 2025); Pulse 2.0, Vanta Series D (Jul 2025); Diligent, AI Act toolkits (Sep 2024); Archer AI Governance; MetricStream release (Apr 2026) (search results); Vanta, startup pricing; Sacra, Vanta at $300M a year (Apr 2026); Vendr buyer data for OneTrust, Vanta, Drata and AuditBoard (updated Feb 2026)
- Acquisitions and security: Veeam, Securiti AI (Dec 2025); Palo Alto Networks, acquisitions; SentinelOne, 10-Q; SecurityWeek, Check Point and Lakera and Cisco and Robust Intelligence; Netskope, fiscal 2026 results (search results)
- Assurance: PwC, Assurance for AI (Jun 2025); Deloitte, AI controls and assurance (Aug 2026) (search results)
Insurance
- Fintech Global, Armilla raises coverage to $25M (Jan 2026); Fortune, AIUC seed round (Jul 2025); Munich Re, AI risks seminar (2026, search result); TechCrunch, AI too risky to insure (Nov 2025)
Reused from earlier guides on this site
- Lab retirement notices, usage policies requiring human review, liability caps, IP indemnities, insurance exclusion forms, the EU Product Liability Directive and the Air Canada ruling: Models and inference and AI agents: orchestration platforms. Reg B adverse-action rules and CFPB withdrawals: Becoming AI native
Field Guides are learning notes, not legal or compliance advice. Rules and fees change; check the cited primary sources before you act on anything here.