For community banks and credit unions · $500M to $10B

Turn your AI policy into a program an examiner can test.

State examiners received the CSBS AI Supervisory Framework on September 16, 2026. We build the evidence it asks for, with your team: the AI inventory, risk ratings, vendor reviews and a board-ready roadmap.

Get the free AI Exam Readiness Checklist Book a 20-minute walkthrough
Examiner evidence map ILLUSTRATIVE
AI governance
Policy, roles, board oversight
Documented
AI inventory
Including vendor-embedded AI
Evidence needed
Generative AI
Staff use and approved tools
Evidence needed
Vendor AI
Third-party AI reviews
Evidence needed

Areas drawn from the document request list in the CSBS Core Examiner Guide. Each state decides how far it applies the framework.

24+ years
Led technology programs at global financial institutions
3 markets
Delivery experience across New Zealand, Australia and the United States
4 weeks
Fixed-fee sprint from AI policy to testable evidence
We build
Implementation, not audit, so your auditor stays independent

Why now

State examiners now have a playbook for AI.

The Conference of State Bank Supervisors released its AI Supervisory Framework for state examiners. It turns AI oversight from a policy conversation into a request for evidence.

Sep 16
Released in 2026
The framework and its Core Examiner Guide went to state examiners on September 16, 2026.
8
Initial scoping questions
Examiners use them to scope how an institution governs and uses AI.
1 list
Document request list
Covers AI governance, AI inventory, generative AI and vendor AI.

Each state regulator decides how far it applies the framework, and examiner judgment applies. We treat it as preparation, not a mandate.

The gap

Writing the AI policy is the easy part. Evidence an examiner can test is the hard part.

WHAT MOST INSTITUTIONS HAVE
An approved AI policy.

A necessary start. On its own, it tells an examiner what you intend, not what you can show.

WHAT AN EXAMINER CAN TEST
An AI inventory, including AI built into vendor products and unapproved staff tools
Risk ratings for each AI use case
Documented reviews of vendor AI
Board oversight, with a roadmap the board has seen
The common blind spot AI that arrives through a vendor update to core, lending or fraud platforms, rather than through a project. Examiners may ask whether you have recognized it.

The engagement

The AI Exam Readiness Sprint

Four weeks. Fixed fee. Five deliverables, built with your team through interviews across departments, so the evidence reflects how your institution actually uses AI.

Discuss your scope
01
AI inventory
Every AI use, including vendor-embedded AI and unapproved staff tools.
02
Use-case risk tiering
A consistent rating for each use, so oversight matches risk.
03
Exam gap map
Your position against the CSBS scoping questions and document request list.
04
Vendor AI review kit
A repeatable way to assess AI inside the products you already use.
05
90-day roadmap
Prioritized next steps, with a briefing prepared for your board.

Scope depends on the number of AI uses and vendors. After a 20-minute walkthrough, you receive a fixed, itemized scope the same week.

How we work

Three steps. The first two are free.

Checklist 10 min · Free

Work through the eight scoping questions on one page and score where you stand.

Walkthrough 20 min · Free

Review your answers with Geet and identify the biggest gaps. No preparation needed.

Sprint 4 weeks · Fixed fee

If there is a fit, you receive a fixed, itemized scope the same week, and we build the evidence together.

Where we fit

Most firms in this space sell software or audits. We do the implementation work.

We build, not just advise

We produce the inventory, risk ratings, vendor review process and board roadmap alongside your team, so the program belongs to you when we leave.

Complementary to your auditor

Auditors must stay independent of the programs they test. We do not audit, so we can build what they will later review.

Alongside your existing tools

Your GRC or vendor-management platform tracks the program. We make sure it is populated with accurate data.

Delivery record

Proven where failure is not an option.

Before founding AI Ascend Partners, Geet led enterprise technology programs at global financial institutions. Two examples from that work, with client names withheld.

CASE STUDY · GLOBAL CUSTODY BANKCLIENT NAME WITHHELD

Replacing a 20-year-old platform without disrupting the business

Situation
A global custody bank needed to replace the 20-year-old corporate actions platform its operations relied on every day.
What Geet led
Program governance across scope, schedule, budget, risk and change control for a program valued at up to $5M, with a globally distributed team of 20+ across business, engineering, testing, migration and production support.
Approach
Current-state discovery, target-state process design, testing, cutover readiness and post-production stabilization.
Outcome
Processing outcomes of up to 99% straight-through processing, enabled by workflow design, controls and automation.

The same sequence of discover, design, prove, cut over and stabilize runs every AI engagement we deliver.

CASE STUDY · GLOBAL BANK · ASIA-PACIFICCLIENT NAME WITHHELD

A multi-market custody rollout across three countries

Situation
A global bank was rolling out direct custody services across Hong Kong, Australia and New Zealand.
What Geet led
Technology delivery as development lead and project manager: planning, development, systems integration, data migration, testing and rollout coordination.
Approach
One delivery plan across markets and time zones, with integration and data migration treated as first-class workstreams.
Outcome
Implementations coordinated and rolled out across all three markets.

Integration and data migration are the hard parts of most AI projects too. That is where this experience pays off.

Who you will work with

Geetanjali (Geet) Gera

CEO & Founder, AI Ascend Partners

Before founding AI Ascend Partners, Geet led large-scale technology programs for global financial institutions across New Zealand, Australia and the United States for more than 24 years. She is a computer science engineer by background.

She brings the delivery discipline of enterprise banking programs to AI governance, and she leads every walkthrough and every engagement personally.

Connect on LinkedIn
24+ years of experience
EXPERIENCE
Led enterprise technology programs at global financial institutions
ROLE
CEO & Founder
Leads every engagement personally
BACKGROUND
Computer science engineer with 15+ years in leadership roles

Questions

What leadership teams ask first

Does this apply to a federal credit union or national bank?

The CSBS framework is written for state examiners, so it applies most directly to state-chartered institutions. Its eight questions remain a useful test for any board overseeing AI, and federal examiners ask about AI through existing reviews such as third-party risk and governance.

Is the framework mandatory?

Each state regulator decides how far it applies the framework, and examiner judgment applies. We describe the work as preparation, not a mandate.

We already have an AI policy. Is that enough?

A policy is the right start. The framework goes a step further, to evidence: the inventory, risk ratings and vendor reviews. The checklist is a quick way to confirm whether those are in place.

Do you replace our GRC platform or our auditor?

No. Your platform tracks the program and your auditor tests it independently. We build the program so both have accurate material to work with.

What does an engagement cost?

It depends on how many AI uses and vendors are in scope, so we do not quote without context. After a 20-minute walkthrough, you receive a fixed, itemized scope the same week.

Free · One page · About ten minutes

See where you stand against the eight scoping questions.

The AI Exam Readiness Checklist turns the framework's questions into yes or no checks, lists the evidence an examiner will want for each, and gives you a simple self-score.

Or book a 20-minute walkthrough with Geet