Banking, lending and fintech

Banks, lenders and fintechs use AI to decide who gets credit, at what price and how fraud is detected, decisions that directly affect people's finances. That is why credit scoring is high-risk in the EU and Peru, a consequential decision in Colorado, and financial supervisors expect AI models to be governed like any other risk.

Relevant sector rules

EU: creditworthiness scoring of individuals is high-risk under Annex III of the AI Act from Dec 2, 2027, with a FRIA for deployers; the Consumer Credit Directive (CCD2) requires human intervention and explanation of scoring from Nov 20, 2026; DORA requires a register of ICT providers, including AI vendors, and the EBA expects model inventories to be extended. Spain: GDPR Art. 22 and CJEU case law on scoring; CCD2 transposition pending. Peru: the Law 31814 regulation classifies credit assessment as high-risk and the finance-sector deadline passed on Sep 10, 2026; the SBS requires model risk management (Res. 053-2023). Ecuador: JPRF and Superintendency of Banks fintech rules (accountable algorithm owner, traceability, explainability and incident reporting) plus the SPDP general rule on AI. Colombia, Mexico, Chile and Argentina: no AI-specific rule from the financial supervisor; data protection and credit-reporting laws apply. Brazil: LGPD Art. 20 (review of automated decisions). US: ECOA/Reg B and FCRA require specific reasons for adverse action; the Fed, OCC and FDIC model risk guidance (SR 26-2) excludes generative AI; Colorado SB 26-189 covers financial services from Jan 1, 2027.

Typical AI uses

Sector regulators

European Union: European Banking Authority (EBA)
Spain: Bank of Spain
National Securities Market Commission (CNMV)
Ecuador: Superintendency of Banks of Ecuador
Financial Policy and Regulation Board (JPRF)
Colombia: Financial Superintendency of Colombia (SFC)
Peru: Superintendency of Banking, Insurance and Pension Funds (SBS)
Mexico: National Banking and Securities Commission (CNBV)
National Commission for the Protection of Financial Services Users (CONDUSEF)
Chile: Financial Market Commission (CMF)
Argentina: Central Bank of Argentina (BCRA)
Brazil: Central Bank of Brazil (BCB)
United States (federal): Consumer Financial Protection Bureau (CFPB)
Federal Reserve Board
Office of the Comptroller of the Currency (OCC)
New York (incl. NYC): New York State Department of Financial Services (NYDFS)
Colorado: Colorado Attorney General

Related kits

Includes 7 documents

Credit and Insurance Kit

Model risk with inventory and materiality, adverse-decision explanation letters, human review, a decision log, technical model documentation and the EU AI Act Art. 26 checklist for high-risk systems.

USD 139USD 253

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