What stood in the way
Commercial credit officers were spending the better part of a week assembling each memo — spreading financials, reconciling covenants, and hand-checking every figure against a 400-page policy manual. The backlog throttled deal velocity, and the manual reconciliation introduced exactly the kind of inconsistency the second line of defense exists to catch. Off-the-shelf copilots had stalled in pilot because nothing in them could survive model risk review.
Credit officers review and approve rather than re-key, so each memo starts from a grounded draft instead of a blank page.
Every figure in a memo is traceable to its source document, so review is faster and the second line can audit with confidence.
The eval harness, documentation, and monitoring are built up front, so a system like this is designed to clear model risk review rather than stall in pilot.