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Strategy

Governance and metrics

Executive readout

Composed from live data · no model

Status 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.

506 of 506 policy checks pass

North star

Days from signed agreement to the partner's first governed report
10business days · target

Controls

Partner-visible metrics traceable to a contract clause
100%
Target
Cardholder-level rows delivered to the partner
0rows
Measured live: 0, asserted by the self-test
Read paths enforced in the database (UI, API, AI)
100%
Measured live: all paths use the same views

Adoption

Questions answered from verified queries
70%
Target
Weekly active data-product consumers
25% QoQ growth
Target

Reliability

Partner report SLA adherence
99.5%
Target
Governed query latency p95
5seconds
Target

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Controls under SR 26-2 (which superseded SR 11-7), fair-lending rules where a credit decision is made, and data-sharing controls.

  • 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).