Sponsor-banked fintechs & non-bank lenders
Regulators have spent three years working through the sponsor-bank sector with consent orders, and every order says the same thing: the bank must evidence oversight of its partners' algorithmic underwriting, fraud and credit pipelines. That obligation now reaches your desk, and weak evidence puts the origination rail at risk.
The forcing function
Cross River (FDIC, 2023), Evolve (Fed, 2024), Blue Ridge (OCC, 2024), Community Federal Savings Bank (OCC, 2026): the recurring theme in sponsor-bank enforcement is third-party and model risk. A bank under that scrutiny cannot accept an informal description of internal review from a partner whose originations flow through its charter. It needs a file it can put in front of an examiner.
The regulatory detail sharpens the request. SR 26-2, which replaced SR 11-7 in April 2026, explicitly carves generative and agentic AI out of scope, leaving banks to govern those systems under their own risk-management principles. In the absence of a checklist, cautious banks ask their partners for more evidence. Adverse-action duties under ECOA and Regulation B continue to apply to every automated decline, and state regulators are actively filling the federal gap.
In Australia the same forcing function arrives as CPS 230 operational-risk obligations and ASIC's scrutiny of third-party AI in credit: a partner bank or funder asking the same questions on different letterhead.
The cost of a weak answer is a frozen origination rail this quarter, not a fine next year.
What the bank's model-risk team asks
Every model, rule set, prompt and vendor score between application and decision, versioned and documented end to end rather than held as informal knowledge.
For any declined applicant, can you reconstruct which stage produced the outcome and the specific reasons given? ECOA / Reg B compliance is assessed decision by decision, not at the policy level.
Are model and prompt changes signed, versioned releases, or informal edits? The bank needs to know the system audited in March is the system running in June.
Aggregate movement in approval rates, pricing and default mix across segments, detected by you before it appears in the bank's own fair-lending review.
Why this passes review
A report from an unfamiliar vendor is a career risk for whoever accepts it. Triodian removes the dependence on reputation: every output a governed system emits carries a signed conformance record bound to a versioned rule set, and your sponsor bank's model-risk team can check that record independently, without dashboard access and without contacting us.
The capabilities behind it are shipped and badged deliverable now on this site: Structured Output Assurance, Bounded Command Governance, the Certifiable Conformance Pack, the Aggregate Drift Service and the Certified Miss-Rate.
Production proof: the governed-reasoning engine and provenance ledger behind these artefacts already run pinpole.cloud, a live commercial platform, at scale.
The first step
A 90-minute structured interview with your risk and engineering leads. The assessment requires no system access, log export or InfoSec review, so nothing about it needs your security team's approval.
Within 7–14 days you receive a Diagnostic Gap Report covering model architecture, data provenance, evaluation pipeline, runtime controls and aggregate-drift exposure, mapped to your bank's audit request or the examiner guidance behind it. It identifies the gaps the bank's reviewers is most likely to raise, so you can close them before the review begins.
| Fee | A$7,500 / US$5,000, fixed |
| Cycle | 7–14 days, interview to report |
| Access | None (interview only) |
| Credit | 50% creditable against the Evidence Pack within 45 days |
The assessment fee is shown in both AUD and USD. Later stages are shown in AUD; US engagements are quoted from the USD price book.
Where it leads
A$25,000 single pipeline · A$35,000 up to three
The direct unblocker: an audit-grade AI model risk, lineage and aggregate-drift Evidence Pack addressed to your sponsor bank, built from historical log exports through an encrypted bucket. No firewall change, inline access or DPIA, so no security review is triggered on your side.
How the evidence is built →A$25,000 sprint + A$5,000/mo per stream
Every individual decision can pass its check while the portfolio drifts toward a mix nobody approved. Set-level governance over each credit and fraud stream, with a Certified Miss-Rate bound and monthly compliance certificates the bank recognises at renewal, plus an annual Evidence Pack refresh at A$12,000.
The Aggregate Drift Service →