Strategy
Governance and metrics
Executive readout
Composed from live data · no modelStatus amber. Partner Aurora's data room is live: 506 of 506 entitlement checks pass against the database; 4 governance items open.
- WinsEntitlements enforced in the database: Program scope, purpose grants and column masking enforced by Postgres on every read path: the simulator, the API and the AI analyst.
- WinsContracted partner aggregates: The partner receives contracted metrics by contracted dimensions; any cell under 25 cardholders is suppressed.
- WinsGoverned AI analyst: Plain-English questions compile through a semantic layer onto masked views. Verified questions cost no model call.
- RisksOngoing monitoring (drift): KS drift 0.041: inside the 0.05 tolerance but rising.
- RisksOffshore and affiliate access to US cardholder data: Residency is not yet a policy attribute.
- AsksAdverse-action reasons (Reg B, 12 CFR 1002.9): Complete reason-code validation before production.
- AsksIndependent validation: Complete the validation report before promotion.
- NextIdentity-bound personas: Replace persona switching with SSO and SCIM identity, with signed claims read by the same policies.
- NextTime-bound unmask exceptions: Request, approve and auto-expire a 15-minute unmask grant, with every step logged.
Metrics tree
Program targets roll up to one north star. Control metrics are measured live where the database can prove them.
North star
Controls
Adoption
Reliability
Model-risk and governance register
Controls under SR 26-2 (which superseded SR 11-7), fair-lending rules where a credit decision is made, and data-sharing controls.
| Control | Model | Status | Finding | Remediation | Owner |
|---|---|---|---|---|---|
| Conceptual soundness (SR 26-2) | Real-time fraud detection | Pass | Development evidence and assumptions reviewed at Tier 1. | - | Model Risk |
| Outcomes analysis | Real-time fraud detection | Pass | Back-test AUC 0.942 on a temporal hold-out (synthetic). | - | Independent Validation |
| Ongoing monitoring (drift) | Real-time fraud detection | Attention | KS drift 0.041: inside the 0.05 tolerance but rising. | Retrain trigger armed at KS drift 0.05. | Fraud Data Science |
| Decline reason codes for servicing | Real-time fraud detection | Pass | Not Reg B adverse action: point-of-sale authorization refusals are excluded (12 CFR 1002.2(c)(2)(iii)). Reasons are available to agents. | - | Fraud Data Science |
| Adverse-action reasons (Reg B, 12 CFR 1002.9) | Credit line increase eligibility | In review | Principal-reason mapping from model drivers under review. | Complete reason-code validation before production. | Compliance |
| Fair-lending testing (BISG proxy) | Credit line increase eligibility | Pass | Adverse impact ratio 0.91 on a BISG proxy, above the 0.80 threshold (synthetic). | - | Fair Lending |
| Independent validation | Cardholder attrition propensity | In review | Validation in progress before production. | Complete the validation report before promotion. | Model Risk |
| Fair treatment of retention offers | Cardholder attrition propensity | Pass | Offer rates consistent across segments. | - | Compliance |
| Partner data minimisation (GLBA and Reg P) | Platform | Pass | The partner receives contracted aggregates only; no cardholder-level rows leave the bank. | - | Data Governance |
| Offshore and affiliate access to US cardholder data | Platform | Attention | Residency is not yet a policy attribute. | Residency-aware entitlements (roadmap: Later). | Data Governance |
- Conceptual soundness (SR 26-2)Pass
Real-time fraud detection · Model Risk
Development evidence and assumptions reviewed at Tier 1.
- Outcomes analysisPass
Real-time fraud detection · Independent Validation
Back-test AUC 0.942 on a temporal hold-out (synthetic).
- Ongoing monitoring (drift)Attention
Real-time fraud detection · Fraud Data Science
KS drift 0.041: inside the 0.05 tolerance but rising.
Remediation: Retrain trigger armed at KS drift 0.05.
- Decline reason codes for servicingPass
Real-time fraud detection · Fraud Data Science
Not Reg B adverse action: point-of-sale authorization refusals are excluded (12 CFR 1002.2(c)(2)(iii)). Reasons are available to agents.
- Adverse-action reasons (Reg B, 12 CFR 1002.9)In review
Credit line increase eligibility · Compliance
Principal-reason mapping from model drivers under review.
Remediation: Complete reason-code validation before production.
- Fair-lending testing (BISG proxy)Pass
Credit line increase eligibility · Fair Lending
Adverse impact ratio 0.91 on a BISG proxy, above the 0.80 threshold (synthetic).
- Independent validationIn review
Cardholder attrition propensity · Model Risk
Validation in progress before production.
Remediation: Complete the validation report before promotion.
- Fair treatment of retention offersPass
Cardholder attrition propensity · Compliance
Offer rates consistent across segments.
- Partner data minimisation (GLBA and Reg P)Pass
Platform · Data Governance
The partner receives contracted aggregates only; no cardholder-level rows leave the bank.
- Offshore and affiliate access to US cardholder dataAttention
Platform · Data Governance
Residency is not yet a policy attribute.
Remediation: Residency-aware entitlements (roadmap: Later).