90
Total Pilot
Duration (Days)
Pilot Design Principle
The pilot is designed as a shadow-mode parallel run during Phase 1 — the agent pipeline processes live applications alongside existing manual workflows but does not replace them. Decision authority shifts to the AI-assisted Credit Officer Workbench only after SR 11-7 validation sign-off at end of Phase 2.
Pilot Engagement Model
CAIBots assigns a dedicated Customer Success Engineer and Compliance Integration Specialist for the full pilot duration. Weekly steering committee check-ins with institution credit leadership. Full documentation package provided at each phase gate.
Prerequisite Checklist
✓
LOSLOS API credentials and sandbox access provisioned to CAIBots integration layer
✓
BureauMCO permissible purpose agreement executed · Test credentialed access confirmed
✓
PolicyCredit policy matrix (Excel/PDF) provided for agent configuration upload
✓
LegalBAA executed · Data Processing Agreement signed · Information Security questionnaire complete
✓
ComplianceFair Lending officer briefed · Model Risk Management notified of SR 11-7 project
✓
TeamPilot team roles assigned (see Section 4) · Calendar holds placed for weekly check-ins
Phase 1 Exit Criteria (Day 30)
≥85%
Decision Alignment
vs Manual
Consumer/HELOC · Shadow run
≤5%
Policy Exception
Rate
Below institution baseline
100%
ECOA Screen
Coverage
Zero unscreened decisions
Phase 2 Exit Criteria (Day 60)
SR 11-7
Model Validation
Sign-Off
MRM approval required
≥90%
Financial Spread
Accuracy
vs CPA/manual benchmark
4.5/5
Credit Officer
UAT Score
Workbench usability rating
Production Go-Live Gate (Day 90)
Go-Live Authorization Checklist
All of the following must be confirmed before production authorization: (1) SR 11-7 Model Validation complete and signed by Model Risk Management Officer; (2) Fair Lending review complete — no disparate treatment signal in parallel test sample; (3) LOS bi-directional integration verified in production environment; (4) Credit staff training completion ≥90% of eligible users; (5) CRO and Chief Compliance Officer sign-off; (6) Incident response and escalation runbook approved by IT Security.
Institution · Sponsor
Chief Risk Officer / CRO
Executive sponsor. Approves pilot scope, phase gates, and production go-live. Reviews SR 11-7 validation results and Fair Lending findings. Final authorization signatory.
Institution · Operations
VP Credit / Chief Credit Officer
Operational owner. Defines HITL thresholds. Reviews shadow-mode accuracy reports. Participates in weekly steering. Approves Credit Officer Workbench design.
Institution · Compliance
Fair Lending Officer / CCO
ECOA/HMDA/CRA compliance review. Reviews fair lending parallel test results. Signs off on Reg B adverse action notice template. Completes Phase 2 compliance gate.
Institution · Risk
Model Risk Management Officer
Leads SR 11-7 model validation. Reviews agent documentation package. Completes validation testing protocol. Issues Phase 2 MRM sign-off for production authorization.
Institution · Technology
IT / LOS Integration Lead
Owns LOS API integration. Provisions credentials for bureau and collateral sources. Manages data security review. Validates production environment pre-cutover.
CAIBots · Engagement
Customer Success Engineer + Compliance Integration Specialist
Dedicated team for full pilot. Owns technical integration, policy configuration, SR 11-7 package preparation, training delivery, and weekly steering facilitation.