PN

Fix the gaps

Remediation

Every failing control, policy and audit in one queue — give each one a plan, an owner and a due date, then track how far along it is.

Open gaps

15

15 total

Without a plan

3

Nobody assigned yet

Past due

11

Plans behind schedule

Average progress

46%

0 closed

Remediation queue

HN-DL-02 — Training data retention and provenance checks

Control · Data Lineage · Card Fraud Detection Engine

PartialIn progress13d overdue

Complete lineage sampling across retained training datasets, reconcile retention exceptions, and attach source-to-model provenance evidence to the control test.

45%

Dataset inventory complete; lineage sampling and exception approvals remain.

Owner M. Chen
HN-FA-01 — Disparate impact testing by protected class

Control · Fairness · Consumer Credit Scoring v4

Failing · test overdueIn progress43d overdue

Re-run protected-class outcome testing on the current credit model, investigate threshold disparities, document mitigations, and obtain Fair Lending approval.

60%

Baseline analysis identified threshold variance; mitigation validation is underway.

Owner D. Osei
HN-FA-02 — Proxy variable screening in features

Control · Fairness · Collections Propensity Model

PartialIn progress20d overdue

Screen production features for direct and correlated proxies, document disposition decisions, remove unsupported variables, and retest model performance.

35%

Feature list has been assembled; correlation review is in progress.

Owner R. Alvarez
HN-FA-03 — Fairness metrics tracked post-deployment

Control · Fairness · Marketing Next-Best-Offer

Not tested · test overdueIn progress48d overdue

Add protected-class fairness indicators to production monitoring, set escalation thresholds, assign alert ownership, and capture the first monitoring report.

25%

Metric definitions approved; dashboard implementation remains.

Owner A. Novak
HN-MR-02 — Annual revalidation of production models

Control · Model Risk · Card Fraud Detection Engine

Partial · test overdueIn progress15d overdue

Complete independent revalidation, challenge assumptions and performance limits, resolve validation findings, and record Model Risk Committee approval.

50%

Validation testing is halfway complete; committee review follows remediation.

Owner M. Chen
HN-MR-04 — Documented model assumptions and limitations

Control · Model Risk · Collections Propensity Model

Failing · test overdueIn progress34d overdue

Refresh the model inventory entries with assumptions, constraints, prohibited uses, monitoring triggers, and business-owner attestations.

40%

Templates are updated; owner attestations and final challenge remain.

Owner R. Alvarez
HN-RS-03 — Change approval with rollback plan

Control · Resilience · Consumer Credit Scoring v4

Partial · test overdueIn progress44d overdue

Document rollback criteria for each production AI service, test one controlled rollback, and attach Change Advisory approval and drill evidence.

55%

Rollback plans are drafted; controlled drill and approval remain.

Owner D. Osei
HN-SC-02 — Prompt injection and output filtering tests

Control · Security · Branch Servicing Assistant (LLM)

Failing · test overdueIn progress53d overdue

Patch the failing prompt-injection scenarios, tune output filters, rerun the security suite, and obtain Security sign-off with retained test evidence.

70%

Filter changes are deployed in staging; regression evidence is pending.

Owner S. Kapoor
HN-TP-01 — Vendor model due diligence refresh

Control · Third Party · Marketing Next-Best-Offer

PartialIn progressin 2d

Collect current vendor assurance reports, review model and data-processing changes, update residual risk, and renew the third-party approval.

20%

Evidence requests sent to vendors; risk review starts after receipt.

Owner A. Novak
Data Lineage & Quality Policy

Policy · BCBS 239 · owned by L. Dubois

Review 28d overdue

No remediation plan yet.

Fair Lending & Model Fairness Policy

Policy · ECOA / Reg B · owned by Priya N.

Review 43d overdue

No remediation plan yet.

Model Change & Resilience Procedure

Policy · SR 11-7 · owned by R. Alvarez

Status expiredIn progress46d overdue

Update the expired procedure for current release gates, rollback ownership and resilience testing, then complete Legal, Risk and Technology approvals before publication.

65%

Draft revision complete; cross-functional approval is in progress.

Owner R. Alvarez
Third Party AI Vendor Policy

Policy · OCC 2013-29 · owned by A. Novak

Status draftIn progress40d overdue

Resolve draft comments, add model-provider monitoring and exit requirements, obtain Procurement and Risk approval, and publish the controlled version.

50%

Stakeholder comments consolidated; final approval and publication remain.

Owner A. Novak
Fair Lending Review — Consumer Credit

Audit · ECOA / Reg B · Consumer Credit Scoring v4

Audit failedIn progress12d overdue

Create a corrective-action response for every audit exception, validate fairness remediation, submit evidence to Internal Audit, and complete independent closure testing.

35%

Management responses are logged; control retesting and closure validation remain.

Owner Internal Audit
Data Governance Assessment

Audit · BCBS 239 · Feature stores and data pipelines

Audit overdue

No remediation plan yet.